Client testimonial advertising rules: what you may publish

You may publish what a client said about you on two conditions: the testimonial was previously made or published, or you are authorized in writing to use it, and you do not distort its scope. That is the Competition Bureau of Canada's rule, and it fits in one sentence. Understanding it takes ten seconds. Respecting it is another matter, because it plays out in the edit suite, on the day a client spoke for four minutes and forty seconds of it are usable.

There is a second rule, less known and more expensive. A testimonial is not proof of a performance claim. "The team was excellent to deal with" is an opinion, and nobody will ask you to prove it. "They cut our costs by 30%" is a performance claim. The fact that a client said it on camera does not supply the proof the law requires. That is the most common mistake in B2B video, and the costliest.

Written authorization or already published: there is no third door

The Bureau states the rule on its advertising guidance page, in its own words.

"Use the results of product performance tests or testimonials in your marketing only if they were previously made or published, or if you are authorized in writing to use them."Competition Bureau Canada, Advertising do's and don'ts, fetched September 23, 2026

A sentence a client published themselves, on LinkedIn or in an online review, was previously made and published. A sentence said to you on the phone at the end of a mandate was not. Everything between those two runs through a written authorization, and that is exactly why a signed release exists in this trade. Where your specific case falls is for your own counsel to say, not for a video supplier.

What this changes for you as a buyer: your supplier should be able to trace every client quote displayed on your site. Where it came from, who said it, who authorized its use, and for which media. Ask for that on the quotes already live, not only on the next shoot. A supplier who "tidied up" a happy client's words with nothing signed left the exposure with you, and it is published under your name.

Second question to settle at signature: does the authorization cover paid advertising, or only your website? A testimonial shot for a home page and later pushed into a campaign changes context and audience. Settle the scope then and there. Reopening it six months later costs weeks, usually in the exact week the campaign was supposed to launch.

The edit: forty seconds pulled from four minutes

This is the part nobody writes about, and it is where the rule actually bites. On the same page the Bureau adds that if you are authorized, you must be careful not to distort the scope of the testimonial. An operations director speaks for four minutes. Forty seconds survive. Choosing those forty seconds is already an interpretation. It is a production problem as much as a compliance one.

Three cuts distort without anyone lying. The first removes the condition: the client said "in our case, at our volumes, it held", and the edit keeps "it held". The sentence becomes a general promise. The second marries two answers filmed twenty minutes apart. Each one is true, and the assembled sentence was never spoken. The third removes the question: an answer to "what worried you before signing" reads differently once the question is gone.

Add subtitles and on-screen text. A caption that cleans up a hesitant sentence rewrites the client. A banner showing a stronger figure than the audio states creates an impression the audio does not support.

What to demand comes down to three things. That the person quoted approves the final edit, not the transcript. That the supplier keeps the full recording and can show where every line came from. That the approval is written and covers the version that will be published, not an intermediate cut. And the answer that should end the conversation: a supplier who offers to rebuild a sentence the client never said, in the edit, in a subtitle or in a caption, because "it lands better that way".

I shoot these interviews myself, so I will say it plainly: the forty most persuasive seconds are almost always the ones a qualifier was removed from. That is where to slow down, not on the shoot day.

A testimonial is not proof of performance

The Bureau ties these rules to two provisions of the Competition Act. Section 74.02 covers the unauthorized use or the distortion of tests and testimonials. Paragraph 74.01(1)(b) covers performance claims: a business making a claim about a product's performance, effectiveness or length of life must be able to prove the claim is based on an adequate and proper test. On the proof itself, the Bureau is blunt.

"Don't make a performance claim unless you can prove it, even if you think it is accurate. Testimonials usually do not amount to adequate proof."Competition Bureau Canada, False or misleading representations and deceptive marketing practices, fetched September 23, 2026

That is the line. A testimonial supports a claim, it does not prove one. A manufacturer in the Québec City region who lines up five client quotes, each with its own percentage, and tops the page with "our clients cut their costs by 30%" has just turned five opinions into a performance claim. It will have to be substantiated some other way, and the quotes will not do it.

The Bureau also weighs the general impression: the court considers both the literal meaning of the information and the general impression it makes. That is why the asterisk rescues nothing. The Bureau states that a disclaimer must not restrict, contradict or negate the message it relates to, and that if the main body of the advertisement already creates a materially false or misleading general impression, fine print may not do much to change it. Put differently: if the result happened once, say so in the claim itself, not in eight-point type underneath.

The amounts are public. For a corporation, a civil penalty can reach the greater of these: $10 million for a first violation, $15 million for each subsequent violation, three times the value of the benefit derived from the deceptive conduct, or 3% of annual worldwide gross revenue. The Bureau also separates criminal provisions, proven beyond a reasonable doubt in court, from civil provisions, decided on the balance of probabilities.

When this page does not apply to you

Some firms should not chase testimonials at all, and it has nothing to do with advertising rules. An aerospace machining subcontractor, a supplier of controlled environments, an integrator working on sensitive processes: their clients simply cannot be named. A confidentiality agreement is not solved with an anonymous quote, and "a manufacturer in the Québec City region" convinces nobody. You lose the credibility without gaining the permission.

Those firms have something better on hand: show the work. The installed machine, the line running, the finished room, the specifications the buyer was looking for in the first place. Visual proof of what you can deliver raises none of the questions above, because nobody is speaking on your behalf in it. The private reference works too: a client who refuses any publication will often take a call with a serious prospect.

Same answer if the only publishable sentence you get is "great service, great team". It is already on your competitors' sites, it proves nothing, and it is not worth the approval cycle it costs. A B2B case study with one approved figure does the job better. When the client does agree to speak on camera, the access and approval constraints are set out on the page about the B2B client testimonial video. The whole logic, from the proof itself through to putting it in front of decision makers, sits on the B2B marketing page.

On our side, the person who shoots the interview is also the person who runs the ad accounts. On this subject that is not a detail: the client's sentence and the ad headline carrying it are decided by the same person, so the gap between the two does not open up as the file moves from one team to another.

This page describes public rules. It is not legal advice. Have your own counsel confirm your situation before you publish.

Sources

• Competition Bureau Canada, Advertising do's and don'ts, competition-bureau.canada.ca, fetched September 23, 2026
• Competition Bureau Canada, False or misleading representations and deceptive marketing practices, competition-bureau.canada.ca, fetched September 23, 2026
• Competition Bureau Canada, Misleading representations and deceptive marketing practices, competition-bureau.canada.ca, fetched September 23, 2026
• Competition Bureau Canada, False or misleading representations, competition-bureau.canada.ca, fetched September 23, 2026