Guide

Reviews and testimonials for law firms: the FTC rule and state bar rules

Last reviewed October 24, 2026 by the Probative editorial team

Reviews do two jobs for a law firm. They help prospective clients choose, and Google says more reviews and positive ratings can help a business’s local ranking (Google). They also sit under three sets of rules at once: the FTC’s federal rule on reviews, Google’s content policy, and your state’s lawyer advertising rules. The good news is that one method satisfies all three. This guide sets it out, with a state table and reply templates. It builds on our lawyer advertising rules guide.

The FTC rule: what it bans

The FTC’s Trade Regulation Rule on the Use of Consumer Reviews and Testimonials took effect on October 21, 2024 and lets courts impose civil penalties for knowing violations (FTC). It sits at 16 CFR Part 465 (eCFR; Cornell LII). For law firms, the parts that matter:

SectionWhat it coversWhat it means for a firm
§465.2Fake or false reviews and testimonials, including buying or selling themNo invented reviews, no review brokers, no AI-written “client” reviews
§465.4Buying positive or negative reviewsNo reward tied to a review’s sentiment, even if disclosed
§465.5Insider reviews by officers, managers, employees and agents, and their relativesStaff and family reviews must clearly disclose the relationship; our rule is that they don’t post at all
§465.6Company-controlled review sitesNo “independent” review site or badge the firm secretly runs
§465.7Review suppression by threats, intimidation or false accusations, including “unfounded or groundless legal threats”Never threaten a former client to get a review removed
§465.8Fake indicators of social media influenceNo bought followers or views

What the rule allows

Two answers in the FTC’s Q&A matter most (FTC):

  • General requests are fine. The rule “exempts generalized solicitations to purchasers for them to post reviews about their experiences,” so asking every client is allowed.
  • Selective asking is still risky. The FTC says asking only satisfied customers could violate the FTC Act even though the rule itself doesn’t ban it.

The rule also doesn’t prohibit incentives that carry no requirement about sentiment, but undisclosed incentives can still violate the FTC Act (same source). For lawyers, other rules close that door anyway, as below.

Google’s rules

Google’s content policy for Maps lists, as fake engagement, offering incentives “such as payment, discounts, free goods and/or services” in exchange for any review, and businesses that “discourage or prohibit negative reviews, or selectively solicit positive reviews” (Google). It also bars reviews from people with a conflict of interest, including current or former employment, and says merchants shouldn’t pressure people to review while on the premises (same source).

Google’s rule is stricter than the FTC’s on incentives: no incentive for any review, positive or not. Follow Google’s.

The lawyer layer: recommendations, testimonials and results

State bar rules add three points the FTC and Google don’t cover.

Rewards look like paying for a recommendation. The ABA’s model rule bars giving anything of value to a person for recommending the lawyer’s services, with narrow exceptions such as nominal thank-you gifts not intended as compensation (ABA Model Rule 7.2). A gift card for a review is hard to square with that. Ask your bar before offering anything at all.

A quoted review becomes a testimonial. A review on Google is the client’s own speech. When the firm copies it onto its website, a landing page or an ad, it becomes the firm’s communication about its services. Then the state’s rules on testimonials apply: some states require disclaimers, some limit testimonials to typical experiences, and Arkansas, per a secondary source, treats any testimonial as making an ad misleading.

Results need context. The ABA’s comment to Rule 7.1 warns that truthful reports of past results can mislead if they lead people to expect the same outcome (ABA Model Rule 7.1). A review that says “they got me $400,000” is a results claim when the firm republishes it. New York dropped its required “Prior results” sentence on June 1, 2026, but its amended Rule 7.1 comment still warns that results can create unjustified expectations and that a disclaimer can help (Rule 7.1, as amended). Florida limits testimonials to real clients with typical experiences, unpaid and not written by the lawyer (Florida Bar).

State rules on testimonials and results

Exhibit A

From Probative's state rules data, claims cells

Testimonial, results and specialist rules in 50 states and DC: 12 checked against primary text, 17 secondary, 22 on the ABA default

StateResults, testimonials and specialist claimsStatus
AlabamaResults objectively verifiable, with the type of matter; testimonials only from people with real experience, paid ones disclosed; no actors playing the lawyer (Rule 7.2(l)-(p), since January 1, 2026)P
AlaskaABA defaultD
Arizona“Certified specialist” only if certified; results disclaimer recommended, not required; client consent to identify a caseP
ArkansasAny testimonial or endorsement makes an ad misleadingS
CaliforniaBans guarantees, undisclosed dramatizations and paid-for awards; in electronic media, results out of context are presumed misleading; portrayed results need facts or a disclosureP
ColoradoABA model: truthful results with context; named, approved certifierP
ConnecticutResults need context; the rule’s comment calls for a disclaimerS
DelawareABA defaultD
District of ColumbiaDamage awards, verdict records and endorsements need qualificationS
FloridaResults objectively verifiable; testimonials only from real clients with typical experiences, unpaid, not drafted by the lawyer; results testimonials carry a “may not obtain same results” statementP
GeorgiaResults can mislead and disclaimers can help; “specialist” if based on real experience, training or certificationP
HawaiiABA defaultD
IdahoABA defaultD
IllinoisNo recognized specialist certifications; “certified” only to name an actual award, with Illinois’s disclaimerP
IndianaABA defaultD
IowaABA defaultD
KansasABA defaultD
Kentucky“Specialist” only if certified by an approved bodyS
LouisianaAny reference to results needs a disclaimer such as “Results May Vary”; paid testimonials disclosedP
MaineABA defaultD
MarylandResults claims say that each case is differentS
MassachusettsABA modelS
MichiganABA modelS
MinnesotaABA defaultD
MississippiABA defaultD
MissouriABA model, plus the every-ad sentenceS
MontanaABA defaultD
NebraskaABA defaultD
NevadaPast results only where the lawyer was lead counsel, stated net of fees, with a disclaimerP
New HampshireABA defaultD
New JerseyComparisons carry the set non-approval statement; awards only as “included in” a named list, with methodologyS
New MexicoABA defaultD
New YorkSince June 1, 2026, results and testimonials answer to the false-or-misleading standard, with no set disclaimer; “certified specialist” only with a named, approved certifier, while “specializes” is allowed if true (Rule 7.1)P
North CarolinaFictional dramatizations potentially misleading unless they follow State Bar guidanceS
North DakotaABA defaultD
OhioNo testimonial ban; unverifiable claims barredS
OklahomaABA defaultD
OregonABA defaultD
PennsylvaniaResults can mislead; “specialist” only through an approved certifier or with a disclosureP
Rhode IslandTestimonials identified as such; payment and non-client status disclosedS
South CarolinaResults-based endorsements say one result “does not necessarily indicate” othersS
South DakotaTestimonials need substantiation and a set no-guaranty statement; paid ones disclosedP
TennesseeABA defaultD
TexasAllowed if not misleading or likely to create unjustified expectations; “Board Certified” only through the Texas board or an accredited bodyP
UtahABA model, simplified in 2020S
VermontABA defaultD
VirginiaABA modelS
WashingtonABA modelS
West VirginiaABA defaultD
WisconsinABA defaultD
WyomingABA defaultD
Source: Probative state rules library, checked 2026-10-24; each state page lists its sources. P = primary source read. S = secondary source; check the official text before relying on it. D = state text not yet checked; the ABA Model Rule default (truthful results with context; 'certified specialist' only through a named, approved body) applies until it is. Not legal advice.

The full library, with every source, is at lawyer advertising rules by state. A “D” row doesn’t mean the state has no rule. It means we haven’t read the state’s own text yet, so plan to the ABA model and ask your bar.

Responding to bad reviews without revealing client information

The ABA’s Model Rule 1.6 bars revealing information relating to a client’s representation without consent or an exception (ABA Model Rule 1.6). ABA Formal Opinion 496 (2021) applies that to online criticism: a negative review alone does not meet the self-defense exception, so a reply that reveals client information goes too far (ABA Formal Opinion 496). The opinion suggests lawyers consider not responding, since a reply can draw attention; if they respond, they can say professional considerations prevent a response, or invite the person to discuss it privately (same source).

“Information relating to the representation” is broad. It includes the fact that the reviewer was a client, what the matter was, and what happened. A reply that says “we got you a great result and you’re still unhappy” breaks it.

Exhibit B

Probative's templates

Review requests and replies that work under the FTC rule, Google's policy and Opinion 496

UseTemplate
Request, email (every client, at matter close)“Thank you for trusting [Firm] with your matter. If you’re willing, we’d value an honest review of your experience with us on Google: [link]. Whatever you write, thank you for your time.”
Request, text (only where the client has agreed to texts)“[Firm]: thank you for working with us. If you’d like to share an honest review of your experience: [link]. Reply STOP to opt out.”
Reply, positive review“Thank you for taking the time to write this.” (No mention of the matter, the result or the client relationship.)
Reply, negative review, option 1No reply.
Reply, negative review, option 2“Our professional obligations prevent us from responding to the specifics of any review. If you would like to talk with us, please call [office number].”
Reply, review from someone who wasn’t a client“We have no record matching this description. If we’re mistaken, please call [office number] so we can talk.” Then flag the review to Google under its policy.
Templates for attorney review. Send requests to every client at the same matter stage. Adjust to your state's rules and your texting-consent records. Not legal advice.

Notice what the requests leave out: no “five stars,” no “if you were happy,” no reward, and no screening question before the link. Those are exactly the things the FTC, Google and the bar rules object to.

Running a review program that holds up

  1. Pick one trigger. For example, the closing letter in every matter, or the day a settlement check clears. Every client gets the request then.
  2. Log every request. A spreadsheet or CRM field with the date sent shows you asked everyone, if anyone ever questions it.
  3. Never gate. No “how did we do?” survey that sends only happy clients to Google.
  4. Keep staff out. No employee, relative or vendor reviews. Say so in the staff handbook.
  5. Moderate, don’t suppress. Flag reviews that break Google’s rules through Google’s tools. Never threaten a reviewer.
  6. Get approval before republishing. Any review you quote on the website or in an ad goes through attorney approval and your state’s testimonial rules.

Reviews also feed the AI answers that now sit on top of local search. Our Google Business Profile guide covers how Ask Maps reads them.

What this means for your firm

  • Ask everyone, the same way, at the same stage. It is the method every set of rules accepts.
  • Remove every incentive. No gift cards, discounts or raffles for reviews.
  • Write a staff rule that employees and their families don’t review the firm.
  • Check your state’s row in Exhibit A before you quote any review on your website or in an ad.
  • Adopt reply templates your attorney approves, and use them every time.
  • Never threaten a reviewer. The FTC rule bars groundless legal threats to suppress reviews.

Probative is AI-first SEO and ads for law firms. Our local SEO service runs review requests on this method, with logged requests and attorney-approved replies, priced on the pricing page. For the wider organic plan, see our law firm SEO guide.

Marketing information, not legal advice. Review and testimonial rules vary by state; check with your bar and your own counsel.

Questions firms ask

Can lawyers ask clients for reviews?
Yes. The FTC's review rule exempts general requests to customers to post reviews about their experience, and Google allows asking. What both forbid is shaping the result: paying for positive reviews, asking only happy clients, discouraging negative reviews, or having staff post reviews.
Can we offer a gift card for a review?
Don't. The FTC rule bars incentives tied to a positive review, Google bars incentives for any review, and for lawyers a reward for a review can look like paying for a recommendation under rules modeled on ABA Model Rule 7.2. A plain thank-you is enough.
Can we put Google reviews on our website?
Usually, but then they become your advertising. Quoting a review on your site or in an ad makes it a testimonial under your state's rules, which may require disclaimers, typical-experience limits or consent. Check your state's row in the table in this guide.
How should a lawyer respond to a bad review?
Without revealing anything about the matter. ABA Formal Opinion 496 says a negative review alone doesn't permit disclosing client information. Options include not responding, a short reply saying professional duties prevent a response, or inviting the person to call the firm.
Can our paralegals or family members leave us reviews?
No. The FTC rule covers insider reviews by officers, managers, employees and agents and their relatives, which must clearly disclose the relationship, and Google's policy bars reviews from people with a conflict of interest. For a law firm, the simple rule is that only clients review.

New guides and notes, by email

At most twice a month. No selling. Unsubscribe in one click.

By subscribing you agree to our privacy policy.

Start with your own numbers.

Free. A person records a 90-second video of what clients see when they search for you, by email within 2 business days. No account access, no call. We take a few each week; if we're full we'll tell you the date. Paid work opens in January 2027.

  1. Free video review

    A 90-second video on your public ads and search presence, made by a person, within 2 business days.

  2. The measurement study, $3,000

    Your numbers, from click to signed case, in 14 business days. 7-day refund; credited if you sign within 30 days.

  3. Choose your plan

    A package or single services, every one with a published price. You own every account.