Understanding the UK’s new crackdown on fake reviews

Online reviews play a huge role in shaping how we shop, travel and make everyday decisions. But when those reviews are fake or misleading, consumers can easily be misled and honest businesses are put at a disadvantage.

To address this, the UK Government has introduced new rules under the Digital Markets, Competition and Consumers Act 2024 (“the Act”). The law, enforced by the Competition and Markets Authority ("CMA"), sets out clear bans on fake reviews and undisclosed incentives, and creates new duties for businesses and review platforms to act responsibly.

Recently, the CMA has published new guidance on fake reviews, providing further clarity for businesses on compliance requirements.

Bans on fake reviews and concealed incentivised reviews

Under the Act, from 6 April 2025, consumer reviews are now unlawful where they are fake or conceal the fact that they have been incentivised.

A fake review is any review that falsely claims to be based on a genuine experience. This applies whether the review is either overly glowing or unfairly negative. Reviews that reflect a person’s genuine experience of a product or service are of course still allowed, and simply disagreeing with a review doesn’t make it fake as long as it reflects a real experience.

The Act also applies to consumer review information that is derived from, or is influenced by, fake or misleading consumer reviews. Examples of this include aggregated information in the form of overall ratings, summaries, review counts and rankings.

An incentivised review is where a review is written in exchange for something of value: money, discounts, free products or samples, preferential rates or commission, or perks like event tickets or hotel stays. An incentivised review is not necessarily in itself unlawful; however, the key requirement is transparency. If the incentive isn’t openly declared, the review could breach the Act.

Legal obligations for businesses

The Act places a positive duty on businesses to act. In other words, businesses and platforms that publish or facilitate the publication of consumer reviews, such as e-commerce platforms, aggregators or business websites, must take proactive steps to prevent and remove fake or misleading reviews, rather than simply abstaining from creating them.

This includes:

• Having clear policies on the prevention and removal of fake and incentivised reviews
• Assessing the risk of these reviews appearing on their platform
• Taking further action beyond having a policy, such as monitoring, moderating and flagging suspicious activity.
• Ensuring published reviews are genuine and not misleading, both at the time of publication and afterwards.

While it is important to suppress fake reviews, a business may also infringe the law if they suppress genuine negative reviews, selectively promote positive reviews for publication over negative reviews, or omit information around how reviews have been written.

Penalties for non-compliance

The Act introduces significant enforcement powers for the CMA, which can now issue fines directly without needing to go through the courts.

Penalties for failing to comply with these new regulations on fake or incentivised reviews include:

• Fines of up to 10% of global annual turnover or £300,000, whichever is higher
• Ongoing fines of up to 5% of daily turnover or £15,000 per day for continued breaches
• Personal liability for directors or managers who knew about or allowed breaches
• Public enforcement notices, which can cause reputational harm

This reflects a major shift toward faster, more forceful enforcement. Businesses ignoring the rules could face not just reputational damage but serious financial and legal consequences.

Impact on consumers and businesses

The Act is a major step forward in cleaning up the online review landscape, protecting consumers from misleading reviews while levelling the playing field for honest businesses.

Complying with the Act is both a legal necessity and a strategic advantage, as it enhances brand integrity and consumer loyalty. With the new reforms, review transparency is no longer optional, placing real responsibility on businesses to ensure reviews are trustworthy and transparent, and empowering regulators to take swift action when they aren't.

Taking the right steps now can keep you compliant and help build trust in an increasingly savvy digital marketplace.

What can we do to help?

For further advice on how your business can ensure compliance with the latest legal developments concerning fake reviews and the Digital Markets, Competition and Consumers Act more broadly, please contact either James Sarjantson on 0113 201 0401 – ku.oc1780700686.fcl@1780700686nostn1780700686ajras1780700686j1780700686 or Thomas Taylor on 0113 204 0407 – ku.oc1780700686.fcl@1780700686rolya1780700686tt1780700686.

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