Paid reviews and disclosure: FTC rules and Google link rules
A sponsored review must say it was paid for, close to the review, in plain words, and its links need rel=sponsored or nofollow. What the FTC bans outright.
LLaunchScaler·Published ·8 min read
A sponsored review must tell readers it was paid for, in plain words, right beside or inside the review, and every paid link in it should carry rel="sponsored" (or rel="nofollow"). What is banned outright in the US is different: fake reviews, paying for a review on condition that it is positive or negative, and undisclosed reviews by your own officers and managers.
Two authorities set these rules. The Federal Trade Commission governs what readers must be told. Google governs how the links in paid content must be marked if you want to stay clear of its link spam policy. This article covers both, with the wording and placement each one accepts.
What does the FTC require a sponsored review to disclose?
The FTC's Endorsement Guides require you to disclose any connection between the reviewer and the seller that readers would not expect and that could change how they weigh the review. Payment, a free product, a discount or a business relationship all count. The disclosure has to be clear and conspicuous.
The Guides are codified at 16 CFR Part 255. The FTC finalised the current version on June 29, 2023, the first revision since 2009. That update added a definition of "clear and conspicuous" and said a platform's built-in disclosure tool might not be an adequate disclosure on its own.
Three sections carry most of the weight for a paid review:
Section 255.0(f) defines clear and conspicuous as "difficult to miss (i.e., easily noticeable) and easily understandable by ordinary consumers." It has to stand out through size, contrast and location, and nothing else on the page may contradict it.
Section 255.5 says a material connection "must be disclosed clearly and conspicuously." The disclosure does not need the full details, but it must "clearly communicate the nature of the connection."
Section 255.1 says endorsements "must reflect the honest opinions, findings, beliefs, or experience of the endorser."
The FTC also answers the question founders outside the US ask. If it is "reasonably foreseeable" that a review will be seen by and affect US consumers, US law applies, and the FTC notes that the UK and many other countries have similar rules.
Questions, answered
What people ask about this
01
Do paid reviews have to be disclosed?
Yes. Under the FTC's Endorsement Guides, a payment, free product or other connection that could affect how readers weigh a review must be disclosed clearly and conspicuously. The FTC says this applies even when the review mentions negatives.
02
What wording counts as a sponsored review disclosure?
Put the disclosure where readers cannot miss it: next to the review or inside it, in words anyone understands. The FTC says a disclosure is more likely to be seen when it sits very close to the endorsement it relates to, and better still when it is part of it. It does not mandate exact wording, only that the disclosure works.
The FTC's guidance for bloggers and reviewers is specific about what works and what does not:
Disclosure
Does it work?
What the FTC says
"Sponsored by [product name]" at the start of the review
Yes
Naming the sponsor is clearer than a bare "Sponsored"
"[Company] paid me to review this" in the first paragraph
Yes
Simple disclosures like "BRAND paid me to tell you about it" are the best
"Thanks to [company] for the free trial"
Yes, if the free trial is all you got
A thank-you only works when it states what was given
"Thanks, [company]!"
No
A thank-you alone doesn't say you got anything
A line at the very bottom of a long post
Risky
Many readers won't read to the very end
A banner at the very top of the page, outside the post
Risky
Readers' eyes go to the headline and picture first
A link labelled "Disclosure"
No
A hyperlinked disclosure is easily avoidable
"#ad" buried in a run of hashtags
No
Readers won't notice "ad" at the end of a combined hashtag
Name the party that actually paid. The FTC's example is a network that labelled paid game reviews "sponsored by" itself: readers could take the network for a neutral party, so the disclosure should name the game's maker instead.
For video reviews the FTC prefers the disclosure at the beginning over the end, and several disclosures during the video over one. If the only disclosure is at the start, neither you nor the seller should share a link that skips past it.
What did the FTC's 2024 fake reviews rule ban outright?
The Consumer Reviews and Testimonials Rule bans fake reviews, buying reviews that must express a particular sentiment, undisclosed insider reviews, fake "independent" review sites a company controls, review suppression through threats, and fake social media metrics. The FTC announced it on August 14, 2024, and it lets the agency seek civil penalties against knowing violators.
The rule sits at 16 CFR Part 465. It was published in the Federal Register on August 22, 2024 and took effect 60 days after publication. The prohibitions, in the FTC's words:
Reviews that "misrepresent that they are by someone who does not exist, such as AI-generated fake reviews," or by someone who never used the product.
"Providing compensation or other incentives conditioned on the writing of consumer reviews expressing a particular sentiment," positive or negative.
Reviews by company officers or managers "that fail to clearly and conspicuously disclose the giver's material connection to the business."
"Misrepresenting that a website or entity it controls provides independent reviews or opinions."
Using "unfounded or groundless legal threats, physical threats, intimidation, or certain false public accusations" to prevent or remove a negative review.
"Selling or buying fake indicators of social media influence, such as followers or views generated by a bot or hijacked account."
Section 465.7 adds a trap for your own site: you cannot present the reviews you display as most or all of your reviews while withholding the negative or lower-rated ones.
Note what the rule does not ban. A review written by a real person who used the product, with the payment disclosed and no condition on what it says, is lawful. The rule draws its line at the condition on sentiment; a disclosed payment on its own is allowed.
How should links in a paid review be marked?
Mark every link in content you paid for with rel="sponsored". Google says links that are "advertisements or paid placements (commonly called paid links)" should use the sponsored value, and that nofollow "is still an acceptable way to flag them, though sponsored is preferred." Values can be combined, for example rel="sponsored nofollow".
The reason is Google's link spam policy. Its examples of buying links for ranking include "exchanging money for links, or posts that contain links" and "sending someone a product in exchange for them writing about it and including a link." Google also names "advertorials or native advertising where payment is received for articles that include links that pass ranking credit." It adds that paid links are "a normal part of the economy of the web" and are fine once qualified with nofollow or sponsored.
The FTC disclosure and the link attribute do different jobs: the disclosure is for readers and the attribute is for Google, so a paid review needs both, and one never substitutes for the other. The full comparison of sponsored, ugc and nofollow is in which rel value to use on paid and user links.
Review markup has its own rule. Google's review snippet guidelines say not to include "fake or undisclosed incentivized reviews" on a page or in its structured data, and they give "reviews written in exchange for a benefit (such as money, discounts, vouchers, or free products) that don't clearly and prominently disclose the incentivization" as an example. For when review markup on your own site can and cannot show stars, see review stars for your own product.
Can a paid review still be critical?
Yes, and it should be free to be. Payment buys the write-up, not the verdict. The FTC's rule targets incentives "conditioned on" a particular sentiment, and the Endorsement Guides require the review to reflect the reviewer's honest opinion. A contract that says "positive review only" crosses the line the 2024 rule draws.
The FTC also closes the opposite loophole. A reviewer asked whether a paid review that lists the product's negatives still needs a disclosure got this answer: "Even if your review mentions one or more negative points, it's still an endorsement." Readers would weigh it differently if they knew about the payment, so it must be disclosed either way.
Discount-for-review programs follow the same logic. The FTC says recipients of a discount code meant to encourage reviews must disclose it, even when the service says a review is "not required," and that a program which materially inflates your average rating may still be deceptive despite the individual disclosures.
How do you commission a review that meets both sets of rules?
Put the rules in writing before any money moves, so the reviewer, the publisher and you agree on the same terms. Use this order:
Agree in writing that the verdict is the reviewer's, with no approval of the conclusion by you. You may correct factual errors about your product; you may not edit the opinion.
Agree the disclosure text and where it goes: in the first lines of the review, naming you as the payer, for example "Sponsored by [your company]."
Agree that every link to your site carries rel="sponsored" or rel="nofollow".
Check the published page yourself. Read the disclosure where a reader would meet it, then inspect the links in the page source.
Never ask customers for reviews in exchange for anything conditioned on the rating, and never have staff review your product without disclosing who they are.
LaunchScaler's Review article is a paid review, and the offer page says so plainly: "Every commissioned piece is labelled as such, on the blog and everywhere it appears." The payment buys the write-up. The page's words are "A review you paid for is still an honest one," and the editor calls the product "as we find it (rough edges and all)." The measured readiness score next to your listing stays exactly as scanned.
It is one permanent indexed page written by an editor, with 3 links back to your site, a slot in the weekly newsletter and a share to the community feed. It costs $59, one time, ordered against a product you have claimed. Order your review if you want a labelled review page that states its commission up front.
The FTC does not mandate exact wording, but it gives examples such as 'This is an ad for BRAND', 'BRAND paid me to tell you about it' and 'Sponsored by XYZ'. A plain 'thank you' to the brand is not enough on its own.
03
Where should the disclosure go in a blog review?
Close to the review itself, ideally as part of it. The FTC warns that readers may miss a disclosure at the very top of the page outside the post or at the very bottom, and a hyperlink labelled 'disclosure' is not clear and conspicuous.
04
Is it legal to pay for reviews?
Paying for a disclosed review is allowed. The FTC's 2024 rule bans fake reviews, compensation conditioned on a review expressing a particular sentiment, and undisclosed reviews by company officers and managers.
05
Should links in a sponsored post be nofollow?
Google asks for paid links to be marked rel="sponsored" and still accepts rel="nofollow". A paid link that passes ranking credit is link spam under Google's policies.
Buyers search '[product] review' before paying. For a new product that result is thin, and your own site can't fill it. Get an indexed third-party review.
Find referral traffic in GA4 under Acquisition, Traffic acquisition, medium referral. Why apps, chats and lost referrers show as direct, and how to fix it.
Put rel=sponsored on paid links, rel=ugc on links your users write and rel=nofollow on links you won't vouch for. A rule per link type, with the markup.
