Why Testimonials Can Create Legal Problems for Coaches
Testimonials work.
They boost conversion rates, provide social proof, and help buyers imagine what’s possible for them.
But that effectiveness is exactly why the Federal Trade Commission (FTC) regulates testimonials so heavily — and why most coaching sales pages accidentally cross legal lines.
Whether you’re selling business coaching, health coaching, life coaching, or any transformational program, you must ensure your testimonials are:
- truthful
- accurate
- not misleading
And that standard applies even when someone else is making the statement.
If you publish it, you’re responsible for it.
Rule #1: Testimonials Cannot Say What You Cannot Say
The first legal rule is simple:
If you’re not allowed to promise it, your testimonials can’t promise it either.
Illegal examples include:
- “I lost 10 pounds in two weeks in her program!”
- “I made $10K in 30 days — guaranteed!”
- “You WILL hit 6 figures if you join.”
Even if a client truly experienced the result, you cannot publish it without the correct context.
Why? Because a reasonable buyer may believe this is the typical outcome, not the exceptional one.
If you cannot legally make the claim in your own copy, you also cannot legally feature it inside a testimonial.
Rule #2: You Must Disclose Who the Person Is and What Influenced Their Review
The viewer needs to understand whether the testimonial is unbiased.
This means you must disclose if:
- the testimonial came from a close friend or family member
- the person received the program for free
- the person received a discount in exchange for a review
- the person was a beta tester
- the testimonial is about you personally, not your paid program
Examples of appropriate disclosures:
- “This reviewer completed the program as part of a beta group at a discounted tuition.”
- “This testimonial was provided by a family member who tested the program but was not compensated.”
- “This testimonial relates to a previous version of the program.”
These disclosures don’t ruin credibility — in fact, they build trust.
Rule #3: Testimonials Must Reflect the Likely Result, Not the Best Result
This is one of the most misunderstood FTC requirements.
Your testimonials, as a whole, must paint an accurate picture of what MOST people experience — not just the highest-achieving clients.
This means:
- You cannot stack your page with only “unicorn results.”
- You cannot imply that exceptional outcomes are typical.
- You must give context so the viewer can determine whether they’re similar to the person in the testimonial.
Why this matters
If your star student doubled her sales because she was already getting 25 discovery calls per week, the viewer must be told that — otherwise, the testimonial is misleading.
A small line like:
“Anne doubled her sales after already having a fully booked calendar of sales calls.”
…is legally protective AND clarifying.
A Better Option: Create Case Studies for Your Best Results
Rather than deleting your exceptional results (which feels counterintuitive), you can showcase them in a different format: case studies.
Case studies allow you to:
- go deeper into the client context
- explain what they brought to the table
- show what factors contributed to their outsized results
- prevent misleading impressions
This format is highly persuasive AND legally compliant.
How to Fix Your Testimonials Without Losing Conversions
The good news: You don’t need to remove testimonials.
You simply need to clarify them.
Here are simple fixes:
Add a one-line qualifier
Examples:
- “This client entered with previous experience.”
- “Results vary depending on level of implementation.”
- “This client received early access as a beta tester.”
Clarify when a testimonial refers to a different offer
Example:
“This testimonial reflects the client’s experience in a previous program with overlapping content.”
Shift emphasis from numerical outcomes to qualitative outcomes
The FTC strongly prefers qualitative outcomes because they’re less easily misleading.
Examples:
- improved confidence
- better structure
- clarity
- accountability
- simplified path
- reduced overwhelm
These are both legally safer and extremely compelling to buyers.
Why Most Coaches Use Testimonials Incorrectly
Inside many coaching programs, you’re taught to:
- collect as many testimonials as possible
- highlight the most impressive wins
- put screenshots everywhere
- prioritize “results” over accuracy
But this creates legal exposure AND attracts the wrong buyers.
When your sales page reflects reality instead of hype, clients:
- trust you more
- have clearer expectations
- are happier once inside
- are less likely to request refunds
- are less likely to initiate chargebacks
Transparency is a conversion strategy.
Bringing It All Together: The Legal Checklist for Testimonials
Here is the full FTC-friendly checklist for your sales page:
- Are you using any testimonial that promises something you legally cannot promise?
- Have you disclosed whether the reviewer is related to you or incentivized?
- Does the testimonial reflect the buyer’s likely result—not just the best ones?
- Do your testimonials include context to help viewers compare themselves?
- Are numerical outcomes described with necessary qualifiers?
- Are your exceptional results repurposed into case studies instead of general testimonials?
If not, it’s time to update them.
What’s Next in the Selling Legally Series
Testimonials are only one place where coaches accidentally break the law.
Next up:
How to Collect Payment Legally in Your Coaching Business (2025–2026 Edition)
Make sure you’re subscribed so you don’t miss that one.
Want Ready-Made Legal Documents for Coaches?
If you’re building or scaling your coaching business, you also need:
- a privacy policy
- terms & conditions
- a legal disclaimer
- a compliant client agreement
- billing + refund terms
You can get all of these inside my free course, Legal in a Weekend.
