Review Gating: What Google and the FTC Actually Prohibit

Review gating is asking only the customers you expect to be happy for a public review, usually by sending a satisfaction survey first and routing the good responses to Google while the unhappy ones land in a private complaint form. Google prohibits it outright: its Maps policy says merchants may not "discourage or prohibit negative reviews, or selectively solicit positive reviews from customers." The FTC's 2024 rule does not use the phrase, but two of its sections land on the practices gating usually travels with.

That gap between "Google bans it" and "the FTC rule bans it" is where most articles on this topic go wrong, often citing the wrong section number while they do it. So here is the actual text of both, what each one covers, what it does not, and the version of asking for reviews that is both compliant and more effective than gating ever was.

What is review gating?

Review gating is any process that screens customers by predicted sentiment before deciding who gets asked for a public review. The classic implementation is a two step flow: an email asks "how did we do?" with a one to five star picker, four and five star clicks go to a page with your Google review link, and one to three star clicks go to a private feedback form that reaches nobody but you. Nothing in that flow is technically difficult, which is why review software has offered it for a decade and why plenty of tools still advertise it as a feature.

The appeal is obvious. Your public rating rises because the only people who reach Google are the ones already inclined to praise you. The cost is equally obvious once you say it plainly: the rating stops describing your business. It describes your filter.

Is review gating illegal?

In the United States it is not a crime, and there is no statute that names it. What it is: a direct violation of Google's review policies, which can cost you reviews or your profile, and a practice that sits close enough to two provisions of the FTC's consumer reviews rule that a business doing it systematically should assume regulatory exposure. The clean answer for a US business owner is that gating is prohibited by the platform whose reviews you are gating, and the federal rule constrains the incentive and suppression tactics that usually accompany it.

What Google's review policy says about gating

Google's Maps user generated content policy is explicit, and it is worth quoting rather than paraphrasing. Merchants may not "discourage or prohibit negative reviews, or selectively solicit positive reviews from customers." Selective solicitation is the definition of gating, so there is no interpretive room here.

The same policy states what you are allowed to do, which matters just as much: merchants may "solicit or encourage the posting of content that does represent a genuine experience, without offering incentives to do so or attempting to influence the rating or the contents of the review." Asking is fine. Asking everyone is fine. Reminding people is fine. Sorting them first is not.

Google's Business Profile help is separately clear about payment: "Offering incentives, like free or discounted goods or services, in exchange for customers to post reviews, change reviews, or remove negative reviews is considered fake & misleading content and is strictly prohibited." A discount code for a review is not a grey area, and neither is a raffle entry.

Enforcement is mostly automated and mostly invisible. Reviews arriving in unnatural patterns get filtered, sometimes weeks after they were posted, and businesses that trip policy systems can lose the ability to display reviews at all. You do not get a warning letter first.

What the FTC rule actually says

The FTC's Rule on the Use of Consumer Reviews and Testimonials, 16 CFR Part 465, was published on 22 August 2024 and took effect on 21 October 2024. Two of its sections matter for anyone running a review program. Neither says "gating," and reading them accurately is more useful than repeating the summaries.

Section 465.4, buying positive or negative consumer reviews. It is a violation for a business "to 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." Note the "or by implication" clause. A campaign that offers a reward and mentions how much a five star review would mean is conditioned by implication, even if nobody writes the condition down.

Section 465.7, review suppression. This is the section most often cited with the wrong number. Paragraph (a) covers using "an unfounded or groundless legal threat, a physical threat, intimidation, or a public false accusation" to stop a review being written or to get one removed. Paragraph (b) is the one that catches on site review displays: it is a violation to materially misrepresent that the reviews shown "in a portion of its website or platform dedicated in whole or in part to receiving and displaying consumer reviews represent most or all the reviews submitted to the website or platform when reviews are being suppressed (i.e., not displayable) based upon their ratings or their negative sentiment."

That paragraph has a carve out worth knowing, because it is what makes moderation legitimate. A review is not treated as suppressed by sentiment when it is withheld under "criteria for withholding reviews that are applied equally to all reviews submitted without regard to sentiment," which the rule illustrates with things like confidential information, defamatory or obscene content, and another person's personal information. Filtering profanity is fine. Filtering three star ratings is not.

So the honest reading: the rule does not create a named offense called review gating. It bans paying for sentiment, and it bans presenting a filtered review section as if it were complete. Selective solicitation on a third party platform is handled by that platform's policy, and by the general deception standard in Section 5 of the FTC Act if the resulting picture misleads consumers. The FTC can seek civil penalties for rule violations; the per violation maximum is adjusted annually for inflation and was reported at $51,744 when the rule took effect.

Gating vs non-gating: what changes in practice

Can you ask customers for positive reviews?

You can ask for a review. You cannot ask for a positive one, and you cannot ask only the people likely to leave one. The distinction is the wording and the audience list, not your intent. "We would love your honest feedback on Google, it takes a minute" is compliant. "If you had a five star experience, please tell Google" is selectively soliciting positive sentiment, and it is the exact phrasing plenty of email templates still use.

Same rule for the audience. Send to every customer who completed a job, not to the segment that scored you highly in a survey. If you want to know how the unhappy ones feel, ask them too, in the same message, and give them somewhere to reply that you actually read.

What to do instead, and why it works better

Gating optimizes the wrong number. Buyers do not read your average and stop, they read the recent reviews and how you handled the bad ones. A 4.7 with 300 reviews and considered replies to the three complaints outsells a 5.0 with 22 reviews, because the second one looks curated and everybody has learned to distrust it. A 2025 BrightLocal survey found 34% of consumers had questioned the authenticity of reviews on major platforms, which is the trust cost of a decade of filtering.

The mechanics that replace gating are unglamorous and they compound:

• Ask everyone, automatically. A request that fires on job completion or delivery beats a human remembering. Volume and recency are what move the number, and both come from consistency rather than from selection.
• Time it to the moment of relief. A few days after delivery, or the day after the problem was solved. Not at the point of sale, when nothing has been experienced yet.
• Remove every click you can. Send a direct review link, not "search for us on Google." A short link in an SMS converts far better than a paragraph in an email, and the same deliverability discipline that keeps an outbound email sequence out of the spam folder applies to review requests sent at volume.
• Send one follow up, then stop. A single reminder roughly doubles response on most lists. A third message annoys people who already decided.
• Reply to the negatives in public. This is the part gating was trying to avoid, and it is the highest value work in the whole category. A specific, non defensive reply tells the next reader how you behave when something goes wrong.

Done properly this is a background process rather than a project. Automated review generation software sends the request by email or SMS to every customer on a trigger you set, and the reviews that come back feed the review widget on your site. No survey gate, no sorting, nothing to explain to a regulator.

Does your on-site widget need to show every review?

It needs to not lie about what it shows. Section 465.7(b) bites when a business misrepresents that the reviews displayed in its review section represent most or all of those submitted while negative ones are held back for being negative. A widget that shows your eight most recent Google reviews is a selection by date, applied without regard to sentiment, and it is not the thing the rule describes.

Where teams get into trouble is the minimum rating filter. Setting a widget to four stars and up, on a page that presents itself as your customer reviews, is suppression by rating. If you use a rating filter, treat that block as marketing quotes rather than a review portal, and keep an unfiltered set reachable, ideally the platform profile itself. Our guide to displaying reviews on your website covers that layout decision, and the review management software page covers monitoring and responding once the volume grows.

What happens if you have been gating?

Stop the survey gate, then send the plain request to everyone. Expect the average to dip, and expect it to matter less than you think, because volume and recency carry more weight with buyers than the second decimal place. Turn off any incentive tied to reviewing. Check what your on-site display filters and whether the page implies completeness. Then go and reply to every unanswered negative review, because responding to negative reviews is what converts the reader who is scrolling for reasons to say no.

The businesses that came out of gating best are the ones that discovered their real rating was fine. The filter was protecting them from four star reviews, which turn out to be the most persuasive reviews on the internet, because they read like they were written by a person.