What the FTC actually said in October 2024
In August 2024 the Federal Trade Commission finalized 16 CFR Part 465 — the Consumer Reviews and Testimonials Rule — and it took effect on October 21, 2024. The rule did not invent a new theory of fraud. It codified what the agency had already been saying through enforcement actions for the better part of a decade, and gave itself the power to seek civil penalties up to $53,088 per violation.
The rule prohibits a list of practices most operators already vaguely knew were a bad idea. Buying fake reviews. Suppressing negative reviews. Republishing reviews of one product as if they were reviews of a different product. Misrepresenting that an insider review came from an independent customer.
But there is one prohibition that surprised a lot of "review software" buyers: the rule explicitly forbids soliciting reviews from a non-representative sample of your customers. In plain English — you cannot screen who you ask. If you only ask the customers you predict will say something nice, the FTC now considers the resulting batch of reviews to be a deceptive practice.
That is what "review gating" means. And that is the thing your tooling is now legally required not to do.
Review gating, as the FTC defines it
Gating is any flow where the software or process predicts how a customer will rate you, and based on that prediction either asks them to post publicly or routes them somewhere private. Common examples:
- "How was your experience? If 4 or 5 stars, please leave a Google review. If 1-3 stars, please tell us privately."
- A landing page that asks the customer to rate first, and only shows the Google button to high raters.
- A campaign that segments your customer list by NPS score and only emails review requests to promoters.
Each of those flows generates a public review distribution that does not represent your real customer experience. The FTC calls that misleading to other consumers, and the new rule makes the agency's existing enforcement posture explicit.
The companies most exposed to this are review-management vendors that built gating into their core flow and then quietly renamed it. Birdeye and Podium have both publicly distanced themselves from the term in marketing copy while keeping mechanically similar flows in their products. Read the Birdeye comparison and the BrightLocal comparison for the specific differences in how each vendor handles this.
What "review routing" means, and why it's different
Routing — the alternative — is a flow where the customer chooses, not the software. Every customer, regardless of how they rated, sees an option to post publicly on Google, Yelp, Facebook, or any other platform you list. Customers who had a worse experience also see a private feedback option, but it is offered to them as an alternative, not imposed on them as a filter.
The mechanic looks similar from the outside. The legal and ethical posture is completely different.
The line is not whether unhappy customers see a private channel. It's whether anyone is blocked from the public one.
A compliant routing flow has three properties:
- Every customer can reach a public review platform with one tap. Not "if they rate above N stars" — every customer.
- The private feedback option, if you offer one, is presented as a choice alongside the public options, not as a replacement for them.
- You are not selectively soliciting — your initial request goes to every customer who completes service, not just the ones you expect to praise you.
If your current tool fails any of those three, you have a compliance problem regardless of what it's marketed as.
Designing a flow your future self won't have to defend
Practical design choices for an operator setting this up:
- Send the same review request to every customer. The cleanest way to defend "non-selective solicitation" is to actually be non-selective. Automate it so it goes to everyone with a completed visit.
- On the rating page, never make the post-public option contingent on the rating. The rating informs the suggestion order (a 5-star rater sees the public buttons first; a 2-star rater sees the private channel first), but both options are visible to both groups.
- Don't delete public reviews you don't like. The FTC rule explicitly covers suppression. The right response to a 1-star review is a thoughtful public reply, not a takedown request.
- Keep records of how the flow looked at the time each review was solicited. If a regulator ever asks, you want to be able to show that your routing logic gave every customer the same options.
The good news is that this design is not just compliant — it converts better. A routing flow that gives unhappy customers a real way to talk to you privately captures issues you can fix and prevents the 1-star reviews you would have gotten if their only option was Google. The flow the FTC requires is also the flow that protects your average rating.
What to ask your current vendor
Three questions you can ask any review-management vendor that will tell you immediately whether their product is gating or routing:
- "If a customer rates 2 stars on the initial prompt, can they still reach my public Google listing from your flow with one tap?"
- "Does the platform send review requests to my entire completed-service list by default, or only to a filtered segment?"
- "If the FTC asked, could you show that the flow is identical for high and low raters in terms of which public platforms they're shown?"
A vendor that hesitates on any of those three should be a vendor you stop paying. The FTC penalty for getting this wrong is bigger than the cost of switching tools.
Where SignalRoute lands
SignalRoute is a routing tool, not a gating tool. Every customer sees the public review options regardless of rating. The private feedback channel is offered as a choice, not enforced as a filter. We would rather lose the 1% of buyers who genuinely want a tool that filters reviews than build something that puts our customers at legal risk.
The full mechanic is on the how-it-works page. If you're switching from a gating-style tool, start a free trial — you can have a compliant flow live in five minutes.
This post was originally published at https://getsignalroute.com/blog/review-gating-vs-routing-ftc.
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