The free-units-for-a-review deal is now a federal problem, not just a Google policy problem
The FTC rule on fake and bought reviews has been in force since late 2024. What it changed for a med spa's review program, and the ask that still works.
The front desk offers ten free units, or a free facial, for a five-star Google review. Every clinic in aesthetics has done it or been tempted, because the clinic across the street clearly is, and its profile shows it.
For years the risk was Google's policy. Incentivized reviews could be filtered, and a profile that got caught could be suspended for weeks. Since October 2024 there is a second risk that most owners have not priced in. The Federal Trade Commission's rule on consumer reviews and testimonials took effect, and it lets the commission seek civil penalties per violation for practices that used to draw, at worst, a takedown.
What the rule actually prohibits
The rule is short and worth reading on the FTC's own site. The parts that touch a med spa:
- Fake reviews. Reviews from people who never received the service, reviews generated by AI and posted as if from a client, and reviews from people who do not exist.
- Reviews bought with a condition on sentiment. Paying, discounting or giving free product in exchange for a review that must be positive, whether the condition is stated or implied. "Leave us five stars and get a free unit" is the textbook case.
- Insider reviews without disclosure. Your injector, your front desk, your mother reviewing under their own names without saying they work for you or are related to you.
- Review suppression. Threatening or pressuring a client to take down a negative review, or hiding negative reviews on a site you control while showing the good ones.
- Bought social proof. Purchased followers or likes presented as real.
There is a nuance that matters. The federal rule targets incentives conditioned on the review being positive. Google's policy is stricter and bans any incentive at all, regardless of what the review says. So the two rulebooks now stack. Google decides whether the review survives. The FTC decides whether you get fined. "Ten units for five stars" fails both.
Why med spas are exposed more than most
Reviews are the product proof in this business. Nobody can see a jawline result on a map pin, so the star count does the selling. Across 53,312 med spa listings, the median clinic has 50 reviews, 45.1% show a perfect 5.0 and 89.4% sit at 4.5 or higher. When the whole market is crowded at the top, the pressure to manufacture is constant.
Three things make it worse here. Memberships mean you see the same clients every month, so tying a perk to a review is always available. Multi-injector clinics have a dozen employees with personal Google accounts and a group chat. And retail add-ons mean there is always a free product to offer.
The audit to run this week
Read your own reviews with a different eye. Look for employees, family, vendors and reps. If someone on payroll reviewed the clinic, ask them to delete it. Google has no way to add a disclosure to a review, so the only clean fix is removal.
Open your review request text. If the words "five star" or "5 star" appear anywhere, rewrite it. The ask can be for a review. It cannot be for a rating.
Walk the front desk. Any sign, card or tablet screen that says "review us and receive" comes down today.
Check your reputation software for gating. Some tools survey clients first and only send the happy ones to Google. That breaks Google's rules and it is exactly the kind of practice the rule is aimed at. Turn it off. Send everyone the same link.
Look at the website testimonials. Real clients, written consent on file, no composites, and no results language that implies a typical outcome unless it is typical.
The ask that still works, and the moment to make it
None of this stops you from asking. It stops you from paying. The ask that works in aesthetics is spoken by the provider, not the front desk, and it lands at a specific moment.
For injectables, the best moment is the two-week follow-up, not checkout. At checkout the client has ice on her face and no result to look at. At the follow-up the result is visible and she is pleased. The injector says: "If this went the way you hoped, a Google review helps people find us instead of the chains. I will text you the link before you leave." Then the front desk sends it while she is still in the building.
"Hi [name], [provider] at [clinic]. So glad you are happy with the result. If you have a minute, here is the direct link to leave a Google review: [link]. Thank you for trusting us."
For facials and body treatments, ask at checkout. For memberships, ask once, at the three-month mark, and never again.
One text, one reminder at 48 hours, no incentive, same message to every client. That is the whole program, and it holds up to any regulator who asks. The timing and scripts in more detail are in the reviews guide, and the benchmark report shows where your review count sits against your state.
A review program built the compliant way is one of the services in the free 14-day trial, any service, no card. Text or call (385) 832-6175.
Steven has spent the last several years running growth campaigns for local service businesses, med spas among them, and builds the benchmark datasets on this site from public Google listings. About the editor