In January 2022, Fashion Nova agreed to pay $4.2 million to settle FTC claims that it blocked negative reviews from its website. In January 2025, the FTC began sending nearly $2.4 million to 148,351 Fashion Nova customers from that money. Since 21 October 2024, a federal rule has turned that kind of conduct into a violation in itself, and the FTC can seek civil penalties of up to $53,088 per violation against knowing violators. This article explains what the Fashion Nova case showed, what the rule bans and where fashion brands face the most exposure.
What Fashion Nova Did
The FTC’s case was the first to challenge a company for failing to post negative reviews. According to the complaint, as TIME reported, Fashion Nova used a third-party review tool that posted four- and five-star reviews automatically and held lower ratings for the company’s approval. From late 2015 until November 2019, it never approved or posted hundreds of thousands of those lower-rated reviews. Fashion Nova said it never suppressed reviews and that it addressed the issue as soon as it learned of it in 2019, and it attributed the unreleased reviews to a third-party vendor’s software.
The final order in March 2022 required the $4.2 million payment and barred Fashion Nova from suppressing customer reviews or misrepresenting them. It also imposed ten years of recordkeeping duties, including copies of complaints about the company’s reviews. The FTC announced the case alongside letters to ten companies that sell review management services, warning them that avoiding the collection or publication of negative reviews violates the FTC Act.
What the Rule Bans
The FTC announced its final rule on 14 August 2024, and the rule at 16 CFR Part 465 took effect on 21 October 2024. The rule covers four families of conduct. It bans fake or false reviews and testimonials, including AI-generated ones and reviews from people who never used the product, and it bans paying for reviews that must express a particular sentiment, positive or negative. It bans insider reviews that do not clearly disclose the writer’s connection to the business, along with company-controlled websites that pose as independent review sources. It bans review suppression through unfounded legal threats, physical threats, intimidation or certain false public accusations, and it bars a business from claiming that the reviews on its site represent all or most submissions when it has suppressed reviews because of their ratings. It also bans selling or buying fake indicators of social media influence, such as bot followers or views.
The FTC left out one proposed provision. The rule does not address review hijacking, where a business reuses reviews written for one product to promote a substantially different one.
Where Fashion Brands Face the Most Exposure
Rating-based moderation carries the clearest risk, because it is the Fashion Nova practice. A brand can still remove reviews that break clear content rules, but it cannot tell shoppers its reviews reflect everything customers submitted when it has filtered by star rating.
Review incentives need care too. A discount code for a review is lawful as long as the offer does not depend on what the review says, and the FTC’s endorsement guidance still expects a clear disclosure of the connection. An offer of “10 percent off for a five-star review” falls squarely inside the ban.
Insider reviews matter for brands that rely on staff, ambassadors and affiliates. A review by an employee or a paid partner must disclose the relationship, and FLJ’s collaboration agreement template gives brands a place to write that duty into the contract. The rule on fake social media indicators reaches brands that buy followers to look more established, and it reaches the agencies that sell them.
Penalties and What They Mean
The FTC can seek civil penalties against knowing violators. The maximum was $51,744 per violation when the rule took effect, and one compliance guide reports that it stood at $53,088 after the FTC’s 2025 inflation adjustment. A campaign that seeds many fake reviews can count as many violations, so the totals climb quickly.
Fashion Nova’s case predated the rule. The FTC pursued it under the general ban on deceptive practices, and the $4.2 million went to consumer redress. Conduct like Fashion Nova’s now falls under a specific rule that carries civil penalties for knowing violations.
A Review Policy That Holds Up
Brands should publish clear moderation criteria and post every review that meets them, whatever its rating. They should never threaten a reviewer with legal action they cannot support. They should separate review incentives from sentiment and disclose them, and they should require insiders to state their connection. Agencies and influencers need vetting for bought followers. Fashion Nova’s order shows how closely the FTC reads a brand’s review records, so keep your own complaint and moderation logs.
The 2022 case warned the industry. The 2024 rule gives that warning a fine that applies to every brand with a product page.
FASHION LAW JOURNAL INSIDER
Join designers, brand founders and fashion lawyers who get the biggest brand battles, IP fights and career moves in fashion law, straight to their inbox.

