Scott Clark

Wow. Something interesting was just brought to my attention regarding self-promotional listicles: in some cases, they may actually be *against the law,* according to FTC rules that took effect in October 2024. There is already precedent for this: A few years back, a company was sued for publishing hundreds of fake "best of" review pages that ranked their own services #1, included fabricated reviews of competitors whose products had never been used, and posted fake reviews on third-party platforms. The BBB eventually censured the company for unsubstantiated claims. (Note: I am being vague/anonymous on purpose 👀 ) This case took place before the FTC formalized these prohibitions, so the legal exposure today would presumably be much worse. I've been researching and writing about self-promotional listicles for months - the "Best [X] Companies" and "Top 10 [Y] Tools" pages where the publishing company ranks itself #1. This has arguably become the most popular GEO tactic over the last year or two because it has worked (surprisingly well) to influence SEO & GEO results. In my articles about this, I've been approaching this as a potential search quality problem. But it turns out the FTC's Consumer Review Rule (16 CFR Part 465) explicitly prohibits several practices that are common in these pages: * Creating a company-controlled site that presents itself as providing independent reviews (§465.6) * Publishing reviews of products or services you've never actually used (§465.2) * Attributing reviews to people who didn't write them (§465.2(a)) And the penalties? Up to $53,088 PER VIOLATION. Plus, each page could be a separate violation (!!) The FTC issued its first enforcement warning letters under this rule in December 2025 to 10 companies. One way to interpret this for SEOs/GEOs: if your client (or your agency) is publishing "best of" listicles that rank themselves #1 based on scores they made up, about products or competitors they never used, on a site that looks like an independent review authority... that's not just a Google quality guidelines issue anymore. It's a potential legal liability. Based on FTC guidance, the line appears relatively straightforward: you can *absolutely publish comparison content that includes your own product.* Just be honest about who you are and don't fabricate reviews of products or competitors you've never used. (BTW, this part is recommended in Google's Reviews guidelines as well.) That said, this might be tricky for most of these listicles, given that the author almost never actually tried and tested competitor products; usually they're just doing research based on publicly available data about the company. I used Claude to put together a quick reference table (see image below) breaking down what's legal and what's not under the FTC rule. (BTW, I’m not a lawyer and this isn’t legal advice; just my interpretation of the FTC’s published rules. If you’re doing this at scale, it’s worth checking with legal counsel.)