Coaching sells outcomes, so its marketing is full of numbers: a client's revenue, a student's first $10,000 month, a screenshot of a Stripe dashboard. Every one of those is an earnings claim in the eyes of the Federal Trade Commission, and since 2023 the rules on how to make them have tightened three times. This entry is a plain summary for founders, not legal advice. Get a lawyer to review your actual pages.
| Rule | What it covers | In force |
|---|---|---|
| FTC Act Section 5 | Any deceptive or unsubstantiated claim, including earnings claims | Always; basis of every enforcement case |
| Endorsement Guides, 16 CFR Part 255 (2023 revision) | Testimonials, typical results disclosure, material connections | In force; updated June 2023 |
| Consumer Reviews and Testimonials Rule | Fake, AI-generated or insider reviews, bought reviews, review suppression | In force since 21 October 2024; civil penalties per violation |
| Proposed Earnings Claim Rule | Written substantiation for any earnings claim by business coaching sellers | Proposed January 2025; not final |
What does a testimonial need to say about typical results?
The Endorsement Guides are direct on this. If an advertiser does not have substantiation that the endorser's experience is representative of what consumers will generally achieve, the advertisement should clearly and conspicuously disclose the generally expected performance in the depicted circumstances. The Guides give an example: a disclaimer such as results not typical, or a statement that these testimonials are based on the experiences of a few people, is not sufficient. The advertiser has to state what people generally get, in numbers.
For a coaching business that means every case study that shows a client's number carries, next to it, a line like: across the 40 clients who completed this program in 2025, the median revenue increase was X, and 20% reached the result shown. If you do not know that number, you cannot use the testimonial as evidence of what buyers should expect. That is the reason tracking results per client is a compliance function as well as a retention one.
What the 2024 reviews rule bans
- Testimonials from people who do not exist, including AI-generated ones, or who did not have the experience described.
- Buying or selling reviews, and paying for a review conditioned on it being positive or negative.
- Reviews by owners, staff or family without a clear disclosure of the relationship.
- Suppressing negative reviews by threat or by selectively publishing only the good ones on a page that claims to show all reviews.
- Fake social media indicators such as bought followers or views used to mislead about influence.
The rule carries civil penalties per violation. Coaching businesses that show community screenshots as social proof should check that every one is a real member, and that any incentive for testimonials (a free month, a gift) was not conditioned on saying something positive.
Material connections: the one most coaches miss
If the person giving the testimonial has a relationship with you beyond being a client, that has to be disclosed. A client who is also an affiliate, a partner who shares revenue, a friend who got the program free, a client you also do paid work for. On this site, for example, Diego builds the website for Ben Kelly of Acquisition Ace, and that is said wherever his results appear.
What the proposed Earnings Claim Rule would add
In January 2025 the FTC proposed a new Earnings Claim Rule and changes to the Business Opportunity Rule that would explicitly cover business coaching, defined broadly as any program that claims to train someone to establish or operate a business. Sellers would need written substantiation for every earnings claim before making it, and would have to hand it over to a consumer on request. The Commission said that anecdotal information or data about a small number of participants would not be a reasonable basis. The rule is not final as of this writing, but the substantiation standard is already what the FTC applies under Section 5.
What enforcement looks like now
In April 2026 the FTC announced that Publishing.com, which sold a self-publishing course at up to $1,995 plus a coaching add-on, would pay $1.5 million to settle allegations of false earnings claims, illusory refund guarantees and testimonials with undisclosed material connections. The final order was approved in July 2026 and requires the company to substantiate earnings claims going forward. The three theories in that case, the earnings claim, the refund guarantee and the testimonial, are the three places most coaching marketing is exposed.
A working checklist for a coaching business
- Every earnings figure in marketing has a document behind it: who, when, what cohort, how measured.
- Every non-typical result carries a typical-results line in numbers, next to the claim, not on a separate page only.
- Every testimonial names a real person who gave written permission, and any relationship or incentive is disclosed.
- No AI-written or composite testimonials, and no reviews from staff or partners without a label.
- The refund policy on the sales page is the refund policy you honour, every time.
- One disclosure page linked from every results claim, and one person who owns keeping it current.
- Results tracked per client so the typical-results numbers are real and can be updated each quarter.
