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FTC Trade Regulation Rule on the Use of Consumer Reviews and Testimonials (16 CFR part 465)

U.S. Federal Trade Commission · United States (federal) (US) · 1 provision encoded · verified against the official source as of 2026-10-04.

Informational data, not legal advice. Summaries and rules have not been reviewed by a lawyer: always verify official law text for decisions. A suggested guard is intended to address each rule; adding it is not a statement of compliance to that law.

AI-adjacent law General privacy or biometric law, included only where AI data flows trigger it; reported apart from AI-specific law.

Official text: www.ecfr.gov, www.federalregister.gov.

Trust and provenance 3 official sources · last verified 4 Oct 2026 · not reviewed by a lawyer · 1 of 1 provision audit-grade · release 2026.10.05

Where this instrument's data comes from, how current it is, and what has and has not been checked. Each provision below has its own panel.

Official sources
Lanes
Binding law — in force 1
Verification
Sources last verified 4 Oct 2026; each provision states how.
Data release
Data release 2026.10.05, data as of 4 Oct 2026, schema 0.3.10.
Legal review
None of the 1 provision has been reviewed by a lawyer; no TwinEthos rule has been legally reviewed yet. Treat each as research to check against the official text; it is not legal advice. Open questions for counsel on them: 1.
Audit standard
1 of 1 provision audit-grade. The audit standard is TwinEthos's own quality bar for provenance, dates, applicability, detectors, fixtures, remediation and licences; it is not a legal review.
Detectors
1 detector, all experimental: written from the rule's text and not yet measured for precision on real code, so treat a hit as a lead to verify. Each provision lists its detectors' known limits.
Changes
  • 2026.10.05 (5 Oct 2026): 1 provision added

Each data release records which provisions changed; the full list is on Changes.

Binding law — in force AI-adjacent law

Do not publish AI-generated reviews or testimonials that misrepresent that the reviewer exists or used the product (16 CFR 465.2)

16 CFR 465.2(a) · official text · In force: applies since 21 Oct 2024 · United States (federal) (US)

A business may not write, create or sell a consumer review, consumer testimonial or celebrity testimonial that materially misrepresents that the reviewer or testimonialist exists, used or had experience with the product, service or business, or what that experience was (16 CFR 465.2(a)), and may not purchase such a review or disseminate such a testimonial about itself when it knew or should have known of the misrepresentation (465.2(b)). The Commission states that AI-generated reviews are covered (89 FR 68034, n. 35). The rule text never mentions AI; it is encoded as AI-adjacent (owner decision D-19, D-11 pattern 1). Detect code that writes model-generated review or testimonial text into a review store or posts it with no real submitting customer.

Trust and provenance not reviewed by a lawyer · audit-grade · source verified 4 Oct 2026 · release 2026.10.05
Lane
Binding law — in force In force: applies since 21 Oct 2024
Official source
16 CFR 465.2(a) · captured 4 Oct 2026 · anchor hash (SHA-256) 87c57e7a019f… · 9 more anchors in the data release
Verification
Quoted text found word for word in the captured official document (4 Oct 2026). Source last verified 4 Oct 2026: checked against the captured official document; not in the weekly watcher's list; checked against the captured document.
Data release
Data release 2026.10.05, data as of 4 Oct 2026, schema 0.3.10.
Legal review
Not reviewed by a lawyer. TwinEthos derived this rule from the official text it cites: treat it as research to check against that text; it is not legal advice. No TwinEthos rule has been legally reviewed yet. Open questions for counsel on this rule: 1.
Audit standard
Audit-grade: meets all 10 checks of the TwinEthos audit standard that apply to it. The audit standard is TwinEthos's own quality bar for provenance, dates, applicability, detectors, fixtures, remediation and licences; it is not a legal review.
Detectors

1 detector (code pattern), experimental: written from the rule's text and not yet measured for precision on real code, so treat a hit as a lead to verify.

Known limits:

  • Generated reviews posted to third-party sites by a separate marketing tool
  • Author ids invented by the generator
  • Review-writing assistants that return a draft to the signed-in customer are compliant when only the customer's submit creates the review; check the submit handler. Synthetic reviews in test fixtures or demo seed data ne…

Who it applies to

  • Duty falls on: organization
  • Businesses (16 CFR 465.1(a)) that write, create or sell consumer reviews or testimonials, including with generative AI, or that purchase reviews or disseminate testimonials about themselves, where the review or testimonial materially misrepresents that the reviewer exists, used the product or had the experience described, for consumers in the United States. In force from 2024-10-21.
  • Not covered:
    • Paragraph (b) (purchasing or disseminating) does not apply to reviews or testimonials resulting from generalized solicitations to purchasers to post about their experiences, or to reviews that appear only because the business hosts consumer reviews (465.2(d)); paragraph (a) (writing or creating fake reviews) has no such exception
  • Whether it applies depends on facts outside the code; a person has to decide.

The guard to add

Never publish model-written reviews or testimonials as a customer's; let a linked customer edit and submit any AI draft.

In review and testimonial features, model output is a draft returned to the signed-in customer (review_draft), and only that customer's submit action creates the review, with author_id and, where available, order_id or a verified-purchase flag. Remove any seeding, persona or marketing job that writes generated reviews or testimonials into the review store or posts them to third-party sites; AI summaries of real reviews are labelled as summaries, never shown as a review.

Where it goes: 1 application source code, 2 data models, 9 AI output handling, 14 user-facing text.

What this provision adds:

  • Writing or creating a fake review is covered whoever posts it; purchasing reviews or disseminating testimonials is covered when the business knew or should have known of the misrepresentation.

Example (Python + OpenAI SDK), before:

text = client.chat.completions.create(model=M, messages=[{'role': 'user', 'content': f'Write a 5-star review of {p.name}'}]).choices[0].message.content
db.reviews.insert_one({'author': fake.name(), 'rating': 5, 'text': text})

After:

draft = client.chat.completions.create(model=M, messages=help_me_write(customer_notes)).choices[0].message.content
return {'review_draft': draft}  # the signed-in customer edits and submits it

def submit_review(user, order, text, rating):
    db.reviews.insert_one({'author_id': user.id, 'order_id': order.id, 'verified_purchase': True, 'text': text, 'rating': rating})

Control: AI-generated consumer reviews or testimonials are published as if written by real customers who used the product. The same guard addresses 1 item with binding law in 1 jurisdiction. Engineering guidance, not legal advice.

Rule id us-ftc-reviews-rule.no-ai-generated-fake-reviews-or-testimonials · review status: primary source derived

Informational data, not legal advice. Summaries are TwinEthos's own words and rules have not been reviewed by a lawyer: check the official text before relying on any of it. A guard addresses an item; adding it is not a statement that your code meets any law.