The FTC's rule on consumer reviews
The rule, 16 CFR Part 465, took effect on October 21, 2024. Two parts touch replies directly. It bans offering anything in exchange for a review that expresses a particular sentiment, whether the condition is stated or implied (section 465.4). And it bans using an unfounded legal threat, a physical threat, intimidation or a knowingly false public accusation to stop a review or get one taken down (section 465.7). Civil penalties can reach $51,744 per violation, the 2024 figure, adjusted each year.10
In a reply, that means no threat of legal action, no public "this is fake" without evidence, and nothing offered on condition of a changed rating. Fixing the problem with no strings attached is different. A refund given because the service failed, whether or not the review changes, isn't tied to the review. Linking a remedy to the review, in public or in private, is the problem.
Paying to have a review taken down
Every major platform bans offering money or anything else to change or take down a review,81415 and it works against the purpose of the FTC's rule, which is to keep the review record honest. Resolve the problem without conditions, then let the customer decide what to do with their review.
Contracts that silence reviewers
The Consumer Review Fairness Act of 2016 voids form-contract terms that bar or restrict honest reviews or charge people for writing them.17
Defamation and privacy
A reply is a published statement by your business. Saying something false and damaging about an identifiable reviewer is a defamation risk, and proving it true often means airing details that should stay private. Talk about your policy and what changed, not about the reviewer: "Our policy is to confirm by text the day before," not "You ignored our reminder." Never add anything about the reviewer that they didn't write themselves, such as a surname, an order or a visit date. In one European case, a data-protection authority took up a complaint against a host who had added guests' full names to a reply.18
General information, not legal advice. For a specific situation, ask a lawyer.