How insurance agents can ask for reviews the FTC-compliant way in 2026

You can ask every client you serve for a review, by text, email, or in person. What you can't do is choose who gets asked, pay for a star count, or pressure anyone over a bad review. Since October 2024 those practices carry federal penalties, and your state insurance department adds testimonial rules on top. This guide covers each rule as it applies to a licensed agent, then gives you a seven-step process to hand to your staff.

The short version

The FTC's Consumer Reviews and Testimonials Rule (16 CFR Part 465) took effect October 21, 2024. It bans fake reviews, incentives tied to sentiment, undisclosed insider reviews, and suppression through threats (FTC Q&A).
A knowing violation carries a civil penalty of up to $53,088 per violation under the FTC's January 17, 2025 inflation adjustment (FTC). The FTC raises the figure each year, so check the current amount before you quote it.
Generalized requests, and even incentives, are allowed if you never require or imply a particular sentiment. Google's Business Profile policy bans incentives and selective asking outright (Google).
State rules built on NAIC Model 570 make you personally responsible for any testimonial you publish (NAIC). California also requires re-confirming testimonials older than one year (California 10 CCR 2536.4).
Texting a review invitation falls under the TCPA, the Telephone Consumer Protection Act, the federal law that governs automated calls and texts. You need consent, and you must honor STOP within 10 business days (FCC 24-24). Private suits run $500 per violation, which a court can raise to as much as $1,500 when the violation was willful or knowing (47 U.S.C. 227).

Before you begin

Set up four things before the first ask. None of them takes more than an afternoon.

A profile on at least one review site you don't control, such as a Google Business Profile or an independent directory.
One written script that goes to every client, word for word.
A texting consent record for any client you plan to text, plus a way to log STOP replies.
A simple log: who you asked, when, through which channel, and any incentive or disclosure involved.

Three sets of rules apply at the same time: the FTC review rule and the FTC's Endorsement Guides, Google's platform policy, and your state's insurance advertising regulation. If you text, the TCPA adds a fourth.

What the FTC review rule says, section by section

The rule is short and built around six prohibitions (Legal Information Institute, 16 CFR Part 465). Here's each one translated into an agent's daily work.

Section 465.2: fake or false reviews

Writing a review yourself, having a friend who was never a client write one, or posting a review that misstates the reviewer's experience are all banned. That includes seeding a new profile with reviews from people who never bought a policy from you.

Section 465.4: buying positive or negative reviews

You may not give or promise anything of value for a review that must carry a particular sentiment, positive or negative. The FTC's Q&A confirms that generalized requests and incentives are allowed when there's no express or implied sentiment requirement. The condition is the problem, not the gift.

Section 465.5: insider reviews

Reviews from officers, managers, employees, or agents of your business, or their immediate relatives, need a clear disclosure of that relationship. This is the section that catches downline agents, meaning agents who sell under your contract, and family members. Step 4 covers how to handle it.

Section 465.6: company-controlled review sites

You may not run a review site you control and present it as independent. A testimonials page on your own website is fine when it's plainly yours. A lookalike "independent agent ratings" site that you own is not.

Section 465.7: review suppression

You may not use threats or intimidation to get a review removed or to stop one from being posted. The section is about pressure, not a polite request to reconsider. Implying you'll sue is pressure.

Section 465.8: fake influence indicators

Buying followers, likes, or views to inflate your apparent standing is banned.

The penalty and the first warning letters

A knowing violation can cost up to $53,088 per violation, raised from $51,744 effective January 17, 2025 (FTC). The FTC adjusts the amount for inflation each year, so check the current number before you quote it to your team.

On December 22, 2025 the agency sent warning letters to 10 companies under the rule (FTC). The letters cited fake reviews, sentiment-conditioned incentives, undisclosed insiders, and suppression, and they quoted that $53,088 figure.

The Endorsement Guides sit alongside the rule

The FTC's revised Endorsement Guides (16 CFR Part 255) were finalized June 29, 2023 by a 3-0 vote (FTC). They address incentivized and employee reviews, suppression of negative reviews, and fake reviews of competitors. They also define "clear and conspicuous."

Section 255.5 says an incentivized review that doesn't clearly disclose the incentive is "likely deceptive." If incentivized reviews inflate your average rating, you owe a further disclosure (Legal Information Institute, 16 CFR 255.5). The Guides aren't the rule itself, but the FTC uses them to decide what counts as deception.

The rule doesn't punish asking for reviews. It punishes steering them.

Step 1: Ask every client the same way

By the end of this step you'll have one script that goes to every client, no matter how the appointment went. That single habit removes the most common violation.

The practice to avoid is review gating: discouraging negative reviews or selectively soliciting positive ones. Google's policy bans it in nearly those words and lists account termination among the penalties (Google). The FTC's guide for marketers lists it as a don't (FTC). Gating alone isn't one of the six prohibitions in Part 465, but once it involves pressure on a reviewer, Section 465.7 applies.

Consider Renee, a final expense agent in Indiana. Her old process sent a "How did we do?" survey after each delivery. Four- and five-star answers went to Google; the rest went to a private form. That is gating. Her new process sends the same one-paragraph note, with the same link, to every client she delivers a policy to.

A neutral request looks like this: "Thank you for letting me help with your policy. If you have a minute, I'd value an honest review of your experience: [link]. Reply STOP to end these texts." It asks every client the same thing, names no star count, and carries the opt-out line you need if it goes by text.

Write the script once and don't vary it by client. Verification: pull the last 20 clients from your CRM (customer relationship management software) and confirm every one received the same message.

Step 2: Time the ask after service and send a neutral link

Review requests go out after the policy is delivered, and they point to a site you don't control. Both habits protect you under different rules.

Send the request after the work is done, not at the kitchen table. Google's policy prohibits pressuring customers to leave reviews while they're on your premises, which covers handing over a tablet at the close (Google). A link sent the next day lets the client answer in private.

Point the link to a neutral profile. Section 465.6 bans presenting a site you control as independent, so keep any reviews page on your own domain clearly labeled as yours. A CRM that sends a fixed template on a fixed trigger keeps the timing consistent. Our guide to the best life insurance CRMs for 2026 compares the options.

Send after delivery, to a profile you don't own. Verification: open your last three requests and confirm each send date falls after the delivery date and each link points to a third-party profile.

Step 3: Decide on incentives before you offer one, and disclose it

Put your incentive policy in writing before anyone on your team offers a gift. For most agents the right policy is "none."

The FTC review rule allows an incentive when it isn't conditioned on sentiment (FTC Q&A). The Endorsement Guides then require the incentive to be clearly disclosed, or the review is likely deceptive (16 CFR 255.5). Google closes the door entirely: an incentive for a Google review violates its policy regardless of what the FTC allows (Google).

There's a third problem specific to insurance. A gift card handed to someone who just bought a policy can raise rebating questions under state insurance law. Rebating is giving a buyer something of value that isn't stated in the policy as an inducement to buy, and state insurance law restricts it. Skipping incentives avoids all three issues at once.

If you do offer one on a platform that permits it, state the incentive in the request and ask the reviewer to mention it in the review. Verification: read your script aloud and confirm it never links the gift to "a great review" or "five stars."

Step 4: Disclose reviews from staff, family, and downline agents

One rule covers this step: if you work for the agency, or you're related to someone who does, you don't review it without saying so. Your whole team should be able to recite it.

Section 465.5 covers officers, managers, employees, and agents of the business, plus their immediate relatives (16 CFR Part 465). An agent in your downline who writes business under your agency is likely an "agent of the business" under that section, so treat the review as an insider review. Back to Renee: her downline agent Marcus leaves a five-star review calling her "the best mentor in the state." Without a disclosure that he sells under her contract, that's an insider review, and her profile carries the risk.

The Endorsement Guides call this a material connection: any business, family, personal, or financial relationship that could affect how a reader weighs the review. Disclose it whenever a significant minority of readers wouldn't expect it (16 CFR 255.5).

The simplest policy is to ask team members and relatives not to review at all. If one does, make sure the relationship appears in the review text, for example, "I'm a licensed agent who writes business under this agency." Never feature it in your marketing.

Team and family don't review without a disclosure. Verification: compare reviewer names against your team roster and confirm every match discloses the relationship in the review text.

Step 5: Text invitations only with consent, and honor STOP

Every review text you send needs a consent record behind it, and every STOP reply must be processed inside 10 business days. The cost of skipping either one adds up fast.

The TCPA gives consumers a private right of action worth $500 per violation, and a court can triple that for willful or knowing violations (47 U.S.C. 227). That is $500 to $1,500 per text, per client. A CRM set to auto-text every new client a review link, with no consent captured, generates those violations at scale.

The FCC's order 24-24, adopted February 15, 2024, lets consumers revoke consent by any reasonable means (FCC). It treats STOP, QUIT, END, REVOKE, OPT OUT, CANCEL, and UNSUBSCRIBE as reasonable on their face. You have 10 business days to honor the request, and you may send one confirmation text. A law-firm summary places the effective date of those revocation rules at April 11, 2025 (BCLP).

Capture consent in writing before the first text, and make STOP handling automatic. Our SMS consent page shows what a clear consent statement looks like. The CRM guide for final expense agents notes which tools log opt-outs without manual work. Verification: text yourself, reply STOP, and confirm the system suppresses the next message.

Step 6: Follow your state's advertising rules before you reuse a testimonial

Run a four-part check before a client's words appear in your ad, website, or social post. The check comes from state law, not the FTC.

Once you copy a review into your own marketing, it becomes a testimonial in an insurance advertisement, and state law takes over. NAIC Model 570 Section 4Q requires that a testimonial be genuine, represent the author's current opinion, apply to the policy advertised, and be accurately reproduced (NAIC). Under Section 4Q, whoever runs the ad "makes as its own" every statement in the testimonial, and any financial interest or benefit the reviewer received must be prominently disclosed.

Section 3B puts responsibility on the producer who created the ad; a producer is the state's term for a licensed agent. The rule reaches you personally through your producer license, not just your agency.

States adopt the model with their own additions. California's 10 CCR 2536.4 applies the same four-part test and calls for a "Paid Endorsement"-style disclosure when the reviewer was compensated. It also requires you to re-confirm any testimonial older than one year (California 10 CCR 2536.4). New York's 11 NYCRR 219.4(b) requires the same genuineness and accuracy, plus disclosure of any financial interest (New York 11 NYCRR 219.4). New York adds one more: a disclosure whenever actors or models present a testimonial.

The details differ by state, so confirm the specifics with your state insurance department before you publish. Check whether your carrier contract adds an approval step, too. Our overview of life insurance license types explains which rules follow which license.

Check all four parts before you publish. Verification: for each testimonial you use, write the four answers (genuine, current, applies to the policy, reproduced accurately) next to it in your log, with the date.

Step 7: Never edit or suppress, and keep records

By the end of this step you'll have a log that can answer a regulator's questions in five minutes.

Leave the reviewer's words alone. "Accurately reproduced" in NAIC Model 570 means no trimming a complaint out of the middle of a quote. When a negative review arrives, reply politely and publicly, and leave it up. Section 465.7 makes threats and intimidation a federal violation, and Google separately bars discouraging or prohibiting negative reviews (Google).

Keep the script, the send dates and channels, consent records, and any incentive disclosures. Add the date you last re-confirmed each testimonial you use in advertising. Under Model 570 Section 3B you carry the responsibility, so the records are your defense. Verification: pick one published testimonial and trace it back to the original review, the client's permission, and the confirmation date.

The do and don't matrix

Situation	Do	Don't	Rule (16 CFR unless noted)
Who you ask	Ask every client, same script	Screen for happy clients first	Google policy; FTC guide
Where the review goes	A neutral profile you don't control	A "ratings" site you own, presented as independent	465.6
Incentives	Skip gifts on Google. Elsewhere: disclose the gift, never tie it to stars, check your state's rebating rule	Pay for five stars or offer a gift only for positive reviews	465.4; 255.5; Google policy
Staff, family, downline	Disclose the relationship, or don't post it	Publish undisclosed insider reviews	465.5
Texting	Get consent first; honor STOP within 10 business days	Auto-text every client with no consent record	FCC 24-24; 47 U.S.C. 227
Negative reviews	Reply politely, leave it up	Threaten, pressure, or demand a takedown	465.7
Timing	Send the link after delivery	Hand over a tablet at the close	Google policy
Reusing a review in ads	Four-part test, disclose any benefit, re-confirm yearly in California	Trim or paraphrase the client's words	Model 570 Section 4Q; CA 10 CCR 2536.4
Records	Log script, dates, consent, disclosures	Rely on memory	Model 570 Section 3B

Questions people ask

Can insurance agents ask clients for Google reviews?

Yes. The FTC review rule allows generalized review requests, and Google's policy allows businesses to ask customers for reviews. The limits are on how you ask. Send the same request to every client, offer no incentive on Google, do no screening, and apply no pressure while the client is in front of you.

Can I give a gift card for a review?

Not for a Google review, because Google bans incentives outright. On a platform that allows them, the FTC permits an incentive that isn't conditioned on sentiment, provided it's clearly disclosed under Section 255.5. A gift to a new policyholder can also raise rebating questions under state insurance law, so most agents are better off without one.

Is review gating illegal or just against Google policy?

Gating directly violates Google's Business Profile policy, and the FTC lists it as a don't in its guidance for marketers. It isn't named as one of the six prohibitions in 16 CFR Part 465; Section 465.7 covers threats and intimidation. A polite filter with no pressure on the reviewer is a Google policy problem first, and an FTC guidance problem second.

Can I ask a client to take down a bad review?

You can ask once, without pressure, and you can respond publicly to correct facts. You can't threaten legal action, withhold service, or lean on the client in any way. That is suppression under Section 465.7, and Google separately bans discouraging negative reviews. Your safest response is a calm public reply and a note in your log.

What to do next

This week, write your one-paragraph review request and load it into your CRM as a fixed template that fires after policy delivery. The incentive policy, the consent record, and the log can follow once that template is live. Every agent listed on Licensedproducer has had license, background, and carrier appointments (a carrier's authorization to sell its policies) checked before appearing. The platform also hosts invited client reviews.