Gifts for Google reviews: NY Op. 1286, Google and the FTC

Don’t give gifts for Google reviews. As of October 25, 2026, New York’s bar says a small gift is allowed, but Google bans gifts for reviews and the FTC bans any gift that depends on a good review. Ask every client the same way, and offer nothing.

Key facts

• New York State Bar Ethics Opinion 1286, dated September 29, 2025, says a lawyer may ask a former client for a Google review and “may offer the former client a nominal gift for doing so,” if the lawyer doesn’t draft the review or tie the gift to its content (NYSBA).
• Google’s Maps content policy says merchants may not “offer incentives - such as payment, discounts, free goods and/or services - in exchange for posting any review” (Google, read October 25, 2026).
• The FTC’s Rule on the Use of Consumer Reviews and Testimonials went into effect on October 21, 2024 and authorizes courts to impose civil penalties for knowing violations (FTC).
• The FTC rule bars incentives conditioned on reviews “expressing a particular sentiment, whether positive or negative” (16 CFR §465.4).
• Our state rules library holds no other state bar opinion on gifts for reviews as of October 25, 2026.

Three rules, three answers

The bar, Google and the FTC each ask a different question. The bar asks whether the gift is pay for a recommendation. Google asks whether the review reflects a genuine, unpaid experience. The FTC asks whether the gift depends on what the review says. A nominal, unconditional gift can pass the first and third tests and still fail Google’s.

The table’s conclusion: Google’s policy is the strictest of the three, so it sets the practical rule for every firm, in every state.

What does New York Opinion 1286 say?

New York’s ethics committee allows a nominal gift for a Google review, with two conditions and one warning. The lawyer may not draft the review or make the gift depend on its content. And the lawyer may not use the former client’s confidential information against them, which matters most in immigration work.

The facts were simple. An immigration lawyer starting a solo practice wanted to ask former clients for Google reviews and “give a small gift (such as a gift card) to each former client who writes a google review” (Opinion 1286). The committee found no advertising or solicitation problem, because a request to a former client fits the rules’ exceptions.

The opinion’s conclusion: the lawyer “may offer the former client a nominal gift for doing so, provided the lawyer does not draft the google review for the client or condition the gift on the content of the review” (same source).

The warning is about confidentiality. A review “may inadvertently reveal confidential information about the former client’s immigration matter or status,” which could reach “the immigration authorities” (same source). The committee also said that whether the plan complies with FTC guidance “is a question of law beyond our jurisdiction” (same source). In other words, the bar answered only the bar question.

New York wrote this before its June 1, 2026 rule rewrite. Nothing in the new rules addresses review gifts, and the opinion hasn’t been withdrawn as of October 25, 2026 (our New York note).

Why a nominal gift isn’t “paying for a recommendation”

The ABA model rule, now in force in Georgia, lets a lawyer “give nominal gifts as an expression of appreciation that are neither intended nor reasonably expected to be a form of compensation for recommending a lawyer’s services” (Georgia Rule 7.2(b)(7)). Georgia’s comment says the gift “may not be more than a token item as might be given for holidays, or other ordinary social hospitality” (same source). Rules like this are why a bar can allow a small thank-you even though paying for a recommendation is banned. See Can lawyers pay for leads? for the rest of Rule 7.2(b).

What does Google’s review policy say?

Google bans incentives for any review, positive or negative, and removes reviews posted because of one. It also bars businesses from discouraging negative reviews or asking only happy customers. A bar opinion doesn’t change any of this, because Google’s policy is a contract term for using Google Maps, not a legal rule.

The policy, read on October 25, 2026, says merchants may not “offer incentives - such as payment, discounts, free goods and/or services - in exchange for posting any review or revision or removal of a negative review” (Google Maps content policy). It treats “incentivized or biased reviews” as rating manipulation, “which are not allowed and will be removed from maps” (same source).

It also bars businesses from trying to “discourage or prohibit negative reviews, or selectively solicit positive reviews from customers” (same source). What it allows: asking for reviews of a genuine experience “without offering incentives to do so or attempting to influence the rating or the contents of the review” (same source).

So a New York firm that follows Opinion 1286 to the letter, a $10 gift card for any review, still breaks Google’s policy. The likely result is lost reviews. For how reviews affect where you show on Google Maps, see our Google Business Profile guide.

What does the FTC review rule say?

The FTC rule bans incentives tied to a review’s sentiment, fake reviews and certain insider reviews. It doesn’t ban every incentive. The FTC’s own Q&A says an unconditional incentive is allowed under the rule, but not disclosing it can still violate the FTC Act. Courts can impose civil penalties for knowing violations.

• Sentiment-based incentives. It is a violation “for a business to provide compensation or other incentives in exchange for, or conditioned expressly or by implication on, the writing or creation of consumer reviews expressing a particular sentiment, whether positive or negative” (16 CFR §465.4).
• Unconditional incentives. The FTC says “the rule does not prohibit giving incentives for reviews, as long as there isn’t an express or implied requirement that the reviews have to express a particular sentiment,” and adds that “failing to disclose incentives could be a violation of the ftc act” (FTC Q&A).
• Disclosure doesn’t cure a five-star bonus. Asked whether a business can pay for 5-star reviews if reviewers disclose the incentive, the FTC answers no: “that conduct would violate section 465.4” (same source).
• Fake reviews. A business may not write or create a review that misrepresents that the reviewer exists, used the service, or had the experience described (16 CFR §465.2).
• Enforcement. The rule “went into effect on october 21, 2024” and “authorizes courts to impose civil penalties for knowing violations”; it gives no private right of action (FTC Q&A).

“Please leave us five stars and we’ll send a gift card” fails all three rule sets. “Here’s a gift card, whatever you write” passes the FTC rule if disclosed, may pass a bar rule like New York’s, and still fails Google’s.

Do other states have a rule on gifts for reviews?

We found no other state bar opinion on gifts for online reviews as of October 25, 2026. Our library’s review cell is set only where a bar has spoken. Testimonial rules are different: once a firm quotes a review in its own ad or on its website, the state’s testimonial rules apply in full.

New Jersey is the clearest example. Its Committee on Attorney Advertising said on September 30, 2025 that “lawyers cannot pay for endorsements or testimonials,” and a testimonial about past results needs the disclaimer “Results may vary depending on your particular facts and legal circumstances.” (NJ Opinion 49). That covers testimonials in the firm’s advertising, not reviews a client posts on Google. But a firm that pays for a review and then quotes it in an ad has a New Jersey problem as well as a Google one. Testimonial rules for every state are in the state rules library and our reviews and testimonials guide.

How to ask for reviews the safe way

1. Ask everyone, at the same point. Pick a moment, such as the closing letter or the final invoice, and ask every client then. Don’t screen for happy ones.
2. Use the same words every time. “If you have a moment, we’d be grateful for an honest review on Google.” No star requests, no suggested text.
3. Offer nothing. No gift cards, discounts, donations in the client’s name or raffle entries tied to reviewing.
4. Warn about privacy. Tell clients they don’t have to mention their case. For immigration, criminal and family matters, say so plainly.
5. Reply without confirming anything. Thank reviewers in general terms. Never confirm that the person was a client or say anything about the matter.
6. Keep a log. Date, client, how you asked. If Google or a bar ever asks, you can show a consistent process.

What this means for your firm

• Google is the strictest rule, so follow Google. A bar that allows a nominal gift doesn’t stop Google removing the review.
• The FTC cares about conditions. Any gift tied to a good review is a federal problem, whatever the amount.
• Consistency protects you. Ask every client the same way, and keep a simple log.

We build review requests into how our clients’ Google profiles are run, with no incentives and no screening. We handle your state’s ad rules for you, on getting found on Google and in AI answers and on Google ads. See where your firm stands, or get a free review of your Google profile.

Last reviewed October 25, 2026 by the Probative editorial team. Marketing information, not legal advice. Google’s policy can change without notice; re-read it before you change how you ask for reviews, and confirm the bar rules with your own counsel.

Data and state pages. Read the opinions in the ethics opinions dataset and check your state on the state rules pages, such as New York and New Jersey.