Turning Finished Jobs Into Reviews and Referrals, Within the Rules

A finished job is the moment a customer knows the most about your work and feels the most goodwill toward you. It's also the moment many businesses pack up, send an invoice and move on. The review that could have helped the next customer choose you never gets written, and the neighbor who needs the same service never hears your name.

Asking for reviews and referrals is legitimate and expected. But the rules have tightened. The Federal Trade Commission's Rule on the Use of Consumer Reviews and Testimonials took effect on October 21, 2024, and Google enforces its own review policies on Maps and Business Profiles.

This guide explains what those rules say, how to build a review and referral habit that stays within them, and where the FTC rule and Google's policies differ. It is general information, not legal advice.

What the FTC rule prohibits

The rule, codified at 16 CFR Part 465, targets deceptive review practices. In plain terms, it is an unfair or deceptive practice for a business to:

• Write, create or sell fake reviews or testimonials that misrepresent whether the reviewer exists, whether they actually used the product or service, or what their experience was (Section 465.2).
• Purchase reviews it knew or should have known were fake, or get such reviews from its own officers, managers, employees, agents or their relatives for posting on third-party sites (Section 465.2).
• "Provide compensation or other incentives in exchange for, or conditioned expressly or by implication on, the writing or creation of consumer reviews expressing a particular sentiment, whether positive or negative" (Section 465.4).
• Have officers or managers write reviews of their own business without "a clear and conspicuous disclosure" of their relationship, or solicit undisclosed reviews from employees and relatives in certain circumstances (Section 465.5).
• Use "an unfounded or groundless legal threat, a physical threat, intimidation, or a public false accusation" to stop a review from being written or to get one removed (Section 465.7).

The FTC's guidance on the rule notes that it "authorizes courts to impose civil penalties for knowing violations."

Where the FTC and Google differ on incentives

This is an easy detail to miss.

The FTC's Questions and Answers on the rule says: "The rule does not prohibit giving incentives for reviews, as long as there isn't an express or implied requirement that the reviews have to express a particular sentiment." It adds that failing to disclose incentives "could be a violation of the FTC Act," and that paying incentives for 5-star reviews on third-party platforms violates Section 465.4 even if reviewers add a disclosure.

Google's policy for Maps is stricter. Its Prohibited and restricted content policy says it does not allow merchants to "Offer incentives – such as payment, discounts, free goods and/or services - in exchange for posting any review or revision or removal of a negative review." Google's Business Profile help page on getting more reviews puts it directly: offering incentives for reviews "is considered fake & misleading content and is strictly prohibited."

The practical takeaway: for Google reviews, offer no incentive of any kind, not even a sentiment-neutral raffle entry or discount. For other platforms, check that platform's own rules as well as the FTC's.

Ask everyone, not just happy customers

A practice sometimes called "review gating" first asks customers how they feel and sends only happy ones to a public review site. Both sets of rules discourage this.

Google says merchants may not "Discourage or prohibit negative reviews, or selectively solicit positive reviews from customers." The FTC's Q&A, asked whether a business can request reviews only from customers it thinks are happy, answers: "The rule does not contain a specific prohibition against such conduct. But this practice could violate the FTC Act."

A private feedback survey is fine as a way to learn and fix problems. Just don't use it to decide who gets invited to review publicly. Invite every customer the same way.

Make the ask well

Within those limits, a good review request is simple, timely and consistent:

1. Time it to the end of the job. Ask when the work is done and the customer has seen the result, or within a day or two after.
2. Make it easy. Google's help page notes you "can ask customers to visit a Google link or scan a QR code." Put the link in your completion text or email and on the invoice.
3. Keep the wording neutral. "Would you share your experience on Google? It helps neighbors find a contractor" is fine. "Please leave us 5 stars" is not.
4. Don't script the content. Google says merchants should not "request that specific content be included," and it specifically lists "Merchants requesting that staff solicit reviews that include specific content, including content that identifies a staff member." So don't ask customers to mention a technician by name.
5. Don't pressure people on site. Google says merchants "should not require or pressure users to leave ratings or write reviews while on the premises."
6. Don't set staff review quotas. Google lists "Merchants requesting that staff solicit a certain number of reviews" as a prohibited practice.

If you send review requests by text, apply the same consent care you use for any business texting, including clear identification and an easy opt-out. The guide "The Missed Call: After-Hours and Missed-Call Text-Back Plans" summarizes the FCC and CTIA framework.

Respond to reviews, including the bad ones

Google's guidance encourages businesses to reply. Its tips include being "professional and polite," keeping replies short, and to "Never share a reviewer's private information or engage in personal attacks." For negative reviews, it suggests acknowledging mistakes, apologizing when appropriate, and inviting the reviewer to resolve the issue by phone or email.

If you believe a review violates Google's policies, you can flag it through Google's reporting tools. What you can't do, under Section 465.7 of the FTC rule, is threaten or intimidate a reviewer to get a review taken down.

Google also notes that "A mix of positive and negative feedback often feels more trustworthy." A few critical reviews with thoughtful replies can show prospects how you handle problems.

Turn happy customers into referrals

Referrals are separate from reviews, and they can be a valuable source of new work for a local business. To encourage them:

• Ask directly at the end of a good job: "If you know anyone who needs this kind of work, we'd be glad to help them."
• Leave something to pass along, such as a card or a short link to your booking page.
• Thank referrers personally when a referral books.

A referral reward is not the same thing as paying for a review. But keep the two separate: don't make a referral reward depend on posting a review, and don't present referral testimonials in your marketing without disclosing any reward or relationship. Under Section 465.5, testimonials from your own employees or managers need a clear and conspicuous disclosure of their relationship to your business when that relationship isn't otherwise clear to the audience.

Key takeaways

• The FTC's Consumer Reviews and Testimonials Rule (16 CFR Part 465) took effect October 21, 2024, and bans fake reviews, sentiment-conditioned incentives, undisclosed insider reviews and review suppression through threats.
• The FTC permits sentiment-neutral incentives with disclosure, but Google prohibits incentives for any review on Maps.
• Invite every customer the same way; selectively soliciting positive reviews violates Google policy and could violate the FTC Act.
• Don't script review content, pressure customers on site or set staff review quotas.
• Reply to reviews professionally, don't threaten reviewers, and keep referral rewards separate from review requests.

Sources

• Federal Trade Commission (eCFR), 16 CFR Part 465, Rule on the Use of Consumer Reviews and Testimonials
• Federal Trade Commission, The Consumer Reviews and Testimonials Rule: Questions and Answers (November 2024)
• Google, Maps User Generated Content Policy: Prohibited & restricted content
• Google Business Profile Help, Tips to get more reviews