The FTC just sent 10 warning letters. A wake up call for every brand

On December 22, 2025, the Federal Trade Commission (FTC) made a quiet but significant move: they issued warning letters to 10 businesses (brands and retailers) regarding potential violations of the new Consumer Review Rule.

While the FTC has not named the companies, the message to the industry is loud and clear: the “wait and see” era is over. Enforcement is here, and the penalties are steep, up to $53,088 per violation. Whether or not your brand received a letter, this development is a critical moment to pause and audit your review strategy.

These warning letters specifically targeted potential violations of the FTC’s Rule on the Use of Consumer Reviews and Testimonials, focusing on deceptive practices that distort the marketplace. The flagged behaviors include generating or purchasing fake reviews, suppressing honest negative feedback to artificially inflate ratings, and failing to disclose material connections, such as reviews written by employees or insiders without proper labeling. Essentially, the FTC is signaling that any attempt to fabricate social proof or manipulate consumer sentiment is a direct liability.

Whether or not your brand received a letter, this development is a critical moment to pause and audit your review strategy. The landscape of digital fraud is changing rapidly, and staying compliant requires constant vigilance.

Here is what you need to know about the new enforcement reality and how we are evolving to meet it.

The AI arms race

One of the most concerning trends flagged by the FTC, and one we see escalating across the industry, is the use of AI to generate user-generated content (UGC).

In the past, fake reviews were often easy to spot (copy-paste text, bots with no profile pictures). Today, Generative AI can create persuasive, human-sounding reviews in seconds. This has created an “arms race” between fraudsters and authenticity platforms.

As AI models get smarter, bad actors are finding new ways to slip through the cracks. However, this is exactly why a “set it and forget it” approach to reviews is dangerous. Reliance on automated filters alone is no longer enough.

Why compliance by design matters more than ever

The warning letters targeted specific behaviors:

• fake indicators of influence
• suppression of negative reviews
• and undisclosed incentives. 

Avoiding these traps isn’t just about having good software; it’s about having the right policies and partner.

No fraud detection system is 100% perfect.

As AI models get smarter, bad actors are finding new ways to slip through the cracks. We see it, and we know our clients see it too. However, this is exactly why a ‘set it and forget it’ approach to reviews is dangerous. Reliance on automated filters alone is no longer enough.

Bazaarvoice is helping our clients navigate this by doubling down on a multi-layered defense:

1. Transparent incentivization: The FTC is cracking down on “pay-for-praise”, giving rewards only for 5-star reviews. Our product sampling solutions are built to collect neutral feedback, ensuring you get authentic reviews (good and bad) with the proper disclosures every time.
   
2. The human element: Because AI can occasionally outsmart automated filters, human moderation combined, remains a critical firewall. Our teams work to catch nuances that algorithms might miss, providing a necessary layer of oversight.
   
3. Zero-tolerance for gatekeeping: Suppressing honest negative reviews is a direct violation of the new rule. We advocate for a transparent approach where negative feedback is published (provided it meets content guidelines), protecting you from accusations of data manipulation.

The multiplier effect of non-compliance

The statutory fine of $53k per violation is headline-grabbing, but the real cost of non-compliance is often the “trust tax.”

If consumers, or regulators, lose faith in the authenticity of your reviews and UGC, the damage to brand equity is often difficult to repair. Legal fees, crisis management, lost customer trust and lost revenue often dwarf the initial fines.

At Bazaarvoice, we aren’t just watching these shifts; we are ahead of them. Our Authenticity and Trust Mark teams continuously evolve our detection models to identify and block the sophisticated AI fraud patterns the FTC is targeting. But technology works best when paired with vigilant internal policy. This is a shared defense: we provide the fortified infrastructure, and we partner with you to ensure your internal teams use it responsibly. Bazaarvoice was founded on a simple premise: genuine feedback moves commerce. We don’t just host reviews; we authenticate them.

Prioritize compliance and trusted partners

While no system is immune to the arms race of digital fraud, Bazaarvoice is engineered with specific guardrails designed to mitigate the exact behaviors the FTC is targeting:

1. Transparent incentivization: We support product sampling and incentivized reviews because they drive volume, but we make disclosure non-negotiable. Our tools automatically apply “Incentivized Review” badges, helping you avoid the “pay-for-praise” trap (rewarding only 5-star ratings) that was a key trigger for the FTC’s recent warnings.
   
2. No gatekeeping: Suppressing honest negative feedback is a direct violation of the FTC Rule. Our moderation standards are built to publish all genuine content, positive or negative, as long as it meets safety guidelines (no profanity, hate speech, etc.). We ensure you get the full picture, not just the highlights.
   
3. Human + AI defense: We use AI to detect fraud, not to create content. Our systems analyze millions of data points to flag suspicious patterns, and we layer human moderation on top to catch the nuances that algorithms might miss.

The new standard: Authenticity is non-negotiable

The era of the wild west in digital reviews is over. The FTC has signaled that they are watching, and they are willing to penalize brands that try to game the system.

For marketers, this is a moment to audit your tech stack. It is critical to ensure your partners are committed to authenticity and compliance, rather than exposing you to unnecessary risk for the sake of a quick win.

If you are a Bazaarvoice client, your UGC strategy is built on a foundation of trust and compliance by design. If you aren’t, ensure you are asking your vendors how they are adapting to these new enforcement standards.

But the fight against fake content is a partnership. We encourage all brands to:

• Review your internal policies: Are your teams accidentally encouraging non-compliant behavior (e.g., asking employees to write reviews without disclosure)?
  
• Check your vendor list: Are you working with other partners who might be using “black hat” tactics to inflate review volumes?
  
• Report suspicious activity: If you see reviews on your site that look “off,” flag them to us. Authenticity is a shared responsibility.

The goal isn’t just to avoid a warning letter. It’s to build a brand that customers can trust.

Is your review strategy compliant?

Read our breakdown of the FTC’s consumer review rule and how to protect your brand.