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Scroll your testimonials page and ask one question about every screenshot: can I prove this person exists, had this experience and said these words?
If the answer is "I think so" for even a few of them, this week matters. On August 14, 2024, the FTC announced a final rule banning fake reviews and testimonials, voted through 5-0.1 Coaching and course sites that lean on walls of screenshots are exactly the kind of place I would audit first.
Treat what follows as education. It is not legal advice. I have run ads for brands that live and die on proof. Here is how I would walk through it.
What does the FTC's fake review rule actually ban?
Six practices, according to the FTC's announcement.1
The list
- Fake or false reviews and testimonials. Creating, selling, buying or sharing reviews from people who do not exist, never had the experience or misrepresent it. The FTC says this includes AI-generated fake reviews.1
- Buying reviews with a sentiment attached. No compensation or incentive conditioned on a positive or negative review.1
- Insider reviews without disclosure. Reviews from insiders must clearly disclose the connection, and officers and managers face added limits on soliciting reviews from relatives or employees.1
- Company-controlled review sites. You cannot present a site you control as independent when it reviews your own products.1
- Review suppression. No baseless legal threats, intimidation or certain false accusations to remove negative reviews.1
- Fake social media indicators. No buying bot followers or views to look bigger, when you knew or should have known they were fake.1
What happens if you break it
The FTC says the rule lets it seek civil penalties against knowing violators, and that it becomes effective 60 days after Federal Register publication.1 I will not put a dollar figure on it because the announcement does not, and your attorney should confirm how it applies to you.
Does this apply to a coach or course creator?
Do not assume you are exempt. The rule is written around businesses and the reviews and testimonials that sell their products and services. A coach with a sales page full of student testimonials is a business with testimonials.
A word on AI
The FTC says the ban on fake reviews includes AI-generated ones.1 It is now easy to write fifty glowing testimonials in a minute, and that is exactly why the temptation is dangerous. A testimonial from a person who does not exist is a fake testimonial no matter how it was produced. Use AI for drafting your own copy if you like, the way I would use it for turning tribal knowledge into SOPs. Never use it to manufacture a customer.
Where coaching sites are exposed
- Screenshots with no name, no date and no way to check them
- "Reviews" a team member or friend wrote
- Testimonials rewritten or "cleaned up" until they say something the person did not
- Bonuses offered in exchange for a five-star post
- A "review site" you own that ranks your own program first
How do you audit a testimonials page?
Go through it like a skeptical buyer, then like a regulator.
- List every piece of proof on your site, sales pages, emails and ads. Screenshots, videos, quotes, case studies, star ratings.
- Trace each one. Find the original message, the person and the date. If you cannot, mark it for removal.
- Check the words. Compare the published text to the original. Any edit that changes the meaning has to go.
- Check the connection. Did you pay this person, give them free access, or are they an affiliate, partner or employee? That needs disclosure.
- Check how you asked. If you offered anything in exchange for a review, make sure it was not tied to a positive one.
- Check what it implies. If a testimonial implies a result most people do not get, it needs context or it comes down.
- Date the audit. Keep a record of what you reviewed and what you changed.
How should you disclose a material connection?
Plainly, and where people will see it.
The FTC's updated Endorsement Guides, announced in June 2023, address fake and incentivized reviews, reviews by employees and when and how to disclose a material connection, with specific guidance for social media.2 The FAQ added 40 new questions and notes that a platform's built-in disclosure tool may not be enough on its own.2
Common connections in the coaching world
An affiliate who earns a commission on a sale, a partner who gets a revenue share, a student who received a free seat, and a team member who is happy with your work all have a connection a buyer would want to know. If knowing it could change how a viewer weighs the endorsement, disclose it near the endorsement, in clear language.
Do "results not typical" disclaimers help?
Less than most people think.
The FTC's Health Products Compliance Guidance, written for health claims but a good model for the principle, says it is not enough that a testimonial represents the honest opinion of an endorser, individual experiences are not a substitute for research, and a "results not typical" disclaimer does not cure a deceptive testimonial.3 The fix is not a smaller disclaimer in a lighter gray. The fix is a more honest claim. I applied the same guidance to clinic ads for compounded semaglutide earlier this month.
Proof is not what you can show. It is what you can defend if someone asks for the original.
What should proof look like now?
Specific, traceable and in context. Context is the new currency of social proof: who this person was, what they did, over what period, and what else was going on.
Alex Hormozi made the underlying point about trust in a video posted on June 4, 2024: "what other people say to them matters way more than what you tell them."4 That is exactly why a fake review is so corrosive. It counterfeits the one signal buyers trust most.
Show the sheet, not only the screenshot
I would rather show how a result was measured than show a bare screenshot. On my own results page, client figures use first names, and I separate contracted revenue, meaning agreements signed, from collected revenue, meaning cash received. That is the standard I try to hold myself to, and the rule is a good reason for everyone to check theirs.
Keep what is real
Real testimonials from real customers, used with permission and lightly edited only for length, are still the strongest proof you have. The goal of an audit is not to strip your site bare. It is to make every piece of proof one you could hand to a stranger and stand behind.
Keep building.Ekai
Questions people ask
What does the FTC fake review rule ban?
It bans fake or false reviews and testimonials, including AI-generated ones, buying reviews conditioned on positive or negative sentiment, undisclosed insider reviews, company-controlled sites posing as independent, review suppression through threats or intimidation, and buying fake social media indicators.
When does the FTC fake review rule take effect?
The FTC says the rule becomes effective 60 days after it is published in the Federal Register.
Can I offer a discount or bonus in exchange for reviews?
You can ask for reviews, but you cannot offer compensation or incentives conditioned on a particular sentiment. The FTC's guidance on incentivized reviews also expects honest disclosure. Ask your attorney before building a review incentive.
Does a 'results not typical' disclaimer protect a testimonial?
No. FTC guidance says a 'results not typical' disclaimer does not cure a deceptive testimonial. The testimonial itself has to be honest, representative or clearly qualified, and backed up.
Sources
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