Any reward tied to a testimonial — a spin-wheel prize, a global coupon, a gift card, store credit — is an incentive under the FTC's 2024 Consumer Reviews and Testimonials Rule. It's allowed, but only if you disclose it properly and don't condition it on positive sentiment. We handle the disclosure for you; this article explains how and what you need to avoid on your side.
Why this matters
The FTC adopted its Consumer Reviews and Testimonials Rule in 2024. It covers any "material connection" between a reviewer and the business being reviewed — including incentives. A failure to disclose is a violation of Section 5 of the FTC Act, with per-violation penalties that add up quickly in class-action contexts.
It applies to both reward modes in this app:
- Global Reward — every submitter gets the same discount code.
- Spin the Wheel — every submitter wins; the wheel picks which value.
The rule in one line
You can offer incentives. You cannot condition them on positive sentiment. You must disclose them clearly.
What we disclose automatically
On the Welcome screen of every reward-enabled form, we render a small incentivized-testimonial disclosure line:
You'll receive a reward from for submitting this testimonial. This is an incentivized testimonial — rewards are given to anyone who submits, regardless of what they say.
For spin-wheel forms, the line reads:
You'll receive a reward from — the wheel decides which value you get, with one spin per email address. This is an incentivized testimonial — rewards are given to anyone who submits, regardless of what they say.
The disclosure is controlled by Reward tab → Reward Display → Include incentivized-testimonial disclosure. It's on by default. Leave it on unless you have your own legal-reviewed disclosure copy elsewhere on the same page.
What to avoid in your own copy
The FTC's staff guidance calls out phrasing that implies positivity is required to collect the reward. Examples that are problematic:
- "Tell us what you loved and get a $10 coupon"
- "Leave a 5-star review to claim your prize"
- "Share your positive experience with us to spin the wheel"
The safer pattern — and what we use in our own default prompts — is value-neutral:
- "Share your experience with "
- "Tell us what you think — good or bad"
- "Submit a testimonial to spin the wheel"
You set the question and prompt copy in Form builder → (your question). Audit those prompts when you first turn on a reward.
Global Reward vs. Spin the Wheel compliance notes
Both modes share the same disclosure infrastructure. The differences:
- Global Reward — the reward code is revealed only after a valid submission. The code is not in the browser payload until the server accepts the testimonial (and respects any video-only gating you set).
- Spin the Wheel — every slice must be a real prize (see Why every spin wins). One spin per email per form, forever.
The spin-wheel mode has one extra compliance concern — the "is this a lottery?" question — which the every-spin-wins design resolves. Read the compliance article for the full argument.
International
- EU Unfair Commercial Practices Directive requires material information (including whether the review is incentivized) to be disclosed clearly and in context.
- UK CAP Code treats incentivized reviews as promotional marketing and requires the material connection to be upfront.
- Germany, France, Italy have additional national rules on influencer / sponsored content — the disclosure line we ship is sufficient for most, but a paid-influencer campaign is a different thing and may need more.
The default disclosure copy meets the common denominator across US / EU / UK. If you run campaigns in Germany for example, your legal team may want to strengthen language to meet the stricter Landgericht case law on hidden advertising.
What happens on the collect page
The disclosure appears:
- On the Welcome screen, below the reward preview card — the customer sees it before they begin.
- Again on the Ready to send summary step, so the customer re-reads the material-connection statement right before they submit.
If you disable the toggle, both disappear. If you do that, you must have your own equivalent notice visible on the same page to stay compliant.