What the FTC fake reviews rule means for med spa review programs, and for what AI summarizes
The reviews an AI assistant reads aloud about your practice are the same reviews a federal rule now polices.
The FTC's Consumer Reviews and Testimonials Rule bans fake reviews, including AI-generated ones, and bans incentives conditioned on a review being positive or negative. For a med spa that means a "free filler for five stars" program is now a federal problem, not a marketing tactic. It also matters for AI visibility, because reviews are among the business details assistants now read directly.
The rule, in the FTC's words
The FTC announced the final rule in August 2024, and it is codified at 16 CFR Part 465. Among its provisions, it prohibits reviews that misrepresent that they are by someone who does not exist, "such as AI-generated fake reviews". It prohibits "providing compensation or other incentive conditioned on the writing of consumer reviews expressing a particular sentiment, either positive or negative". And it prohibits using groundless legal threats, intimidation or certain false public accusations to remove a negative review. The FTC can seek civil penalties against knowing violators.
Programs that are now off the table
Three common med spa practices run straight into it:
- A reward for a good rating. A free syringe, loyalty points or a discount "for your five-star review" is an incentive conditioned on sentiment. The FTC's question and answer guidance adds that you cannot suggest a review must be positive to earn the reward "even if you don't say so explicitly".
- Staff or friends posing as patients. Reviews from people who were not patients, or written by software, are exactly what the rule names.
- Threatening an unhappy reviewer. A legal letter meant to scare someone into deleting a critical review, without real grounds, is the suppression the rule covers.
One practice sits in a gray zone. Asking only the patients you think are happy is, per the same FTC guidance, not specifically prohibited by the rule itself but "could violate the FTC Act". We would not build a program on that distinction.
Why this is an AI visibility question too
Reviews no longer stay on the review site. Yelp said in August 2026 that it brings "Yelp's trusted reviews, ratings, photos, and business details directly within the chat experience" of ChatGPT, in its own announcement. Google's AI features draw on its index across many sources. So when someone asks an assistant which med spa to trust, the review record is part of what gets summarized.
That changes the math on a gamed review profile. The risk is simple: an assistant that summarizes inflated reviews sets an expectation the practice then fails to meet in the chair. Our reputation signals pillar covers how reviews function as evidence rather than decoration.
A review request that is clean
Ask everyone, the same way
Send the same request to every patient after a completed treatment, not only the ones who smiled at checkout.
Ask for honesty, not stars
"We would value an honest review of your visit" is clean. "Please leave us five stars" is not what you want in writing anywhere.
No reward tied to the rating
If you offer anything at all for a review, it cannot depend on what the review says, and it should be disclosed. The simplest policy is no reward.
Answer criticism in public, carefully
A calm reply to a critical review does more for trust than a removal fight. It also has its own privacy rules, covered in replying to reviews without breaking HIPAA.
What to do
Pull up every review request template your practice and your software send, including automated texts from the booking system, and read them as the FTC would. Remove any reward tied to a rating and any wording that steers toward a score. Write down the policy in one paragraph so new staff do not reinvent the old one. The rest of the cluster is on the med spa guide.
Not medical or legal advice. This is how AI systems read a med spa in public; the rules that bind your practice come from your state board and your own counsel.
Questions
Can a med spa offer a free treatment in exchange for a five-star review?
No. The FTC's Consumer Reviews and Testimonials Rule, 16 CFR Part 465, prohibits giving compensation or any other incentive conditioned on a review expressing a particular sentiment, positive or negative. An offer of free filler or a discount for a five-star review is conditioned on sentiment. The FTC's own guidance adds that a business cannot imply a review must be positive to earn a promised incentive, even without saying so outright.
Can a med spa ask only happy patients to leave reviews?
The FTC's question and answer guidance on its reviews rule says that asking only customers you believe are happy for reviews is not specifically prohibited by the rule itself, but could violate the FTC Act. A med spa that filters who is asked is also shaping the set of reviews that AI assistants later summarize, which makes the summary less accurate and the practice more exposed.
More questions from med spas
This page is part of AI visibility for med spas, the AIOInsights guide to how AI systems find, read and describe this kind of practice.
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- How can a med spa reply to reviews without breaking HIPAA?
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- Where AIO falls short for med spas