Online reviews in the EU and the UK: what the rules on fake and incentivised reviews require

Why regulators focus on reviews

Customers use star ratings and written reviews as a shortcut when choosing products, hotels, restaurants, trades and professional services. That makes reviews valuable to businesses and attractive to manipulate: buying positive reviews, suppressing negative ones, posting reviews from staff or family, or offering discounts only for five-star feedback.

Consumer authorities in Europe and the United Kingdom have treated these practices as misleading commercial practices for years. Recent legislation has made the rules more explicit and, in the UK, much easier to enforce.

The EU rules

The Unfair Commercial Practices Directive, amended by the Omnibus Directive, has applied since 28 May 2022. Where a trader provides access to consumer reviews of products, it must inform consumers whether and how it ensures that published reviews come from consumers who have actually used or purchased the product. Stating that reviews are genuine without taking reasonable and proportionate steps to check is prohibited.

The directive also added two practices to its list of those considered unfair in all circumstances: submitting or commissioning others to submit false consumer reviews or endorsements, and misrepresenting consumer reviews or social endorsements in order to promote products, for example by publishing only positive reviews and deleting negative ones while implying the selection is complete.

Member states enforce these rules through national consumer authorities and courts, and the Omnibus Directive introduced harmonised criteria for penalties, including fines of at least 4% of annual turnover in the member states concerned for widespread infringements coordinated at EU level.

The UK rules

The Digital Markets, Competition and Consumers Act 2024 replaced much of the UK’s previous consumer protection regulations. Its consumer enforcement provisions came into force on 6 April 2025. The Act adds banned practices relating to fake reviews, including submitting or commissioning fake reviews, commissioning or incentivising reviews that are concealed as such, and publishing consumer reviews in a misleading way.

Businesses that publish consumer reviews must take reasonable and proportionate steps to prevent and remove fake reviews and concealed incentivised reviews, and to prevent reviews being presented misleadingly. The Competition and Markets Authority published guidance on what such steps can look like.

The most significant change is enforcement. The Act gives the CMA power to decide whether consumer law has been breached and to impose fines directly, of up to 10% of a business’s global turnover, without first going to court.

Practices that create risk

Some review tactics that were common a few years ago now carry clear legal risk in both markets. The safest assumption is that anything designed to make ratings look better than genuine customer experience would justify is a problem.

Buying reviews

Paying people or services for reviews of products they have not used.

Staff and family reviews

Reviews from employees, owners or relatives presented as independent customers.

Conditional incentives

Discounts, prize draws or gifts offered only for positive reviews, or incentives that are not disclosed.

Review gating

Sending only satisfied customers to public review sites while routing unhappy customers to private feedback.

Selective publishing

Hiding or delaying negative reviews on your own site while implying all reviews are shown.

Misleading displays

Showing ratings from a different product, merging reviews across unrelated products, or quoting reviews out of context.

Designing a compliant review programme

Ask every genuine customer, not only the happy ones, and ask at a consistent point, for example after delivery or after a service is completed. Automated requests from an order or booking system are easier to evidence as fair than manual selection.

If you offer an incentive, offer it for leaving a review regardless of its content and disclose it clearly alongside the review. Many platforms prohibit incentives altogether, so check the rules of the review sites you use as well as the law.

On your own website, publish a short explanation of how reviews are collected, whether they are verified and how moderation works. Moderate for legitimate reasons such as offensive language, personal data or irrelevance, apply the same rules to positive and negative reviews, and keep records of moderation decisions.

Train staff and agencies. Many breaches start with a well-meant instruction from a manager to get more five-star reviews, or with an agency using tactics the business never examined. Contracts with marketing and reputation providers should prohibit fake and concealed incentivised reviews explicitly.

Responding to reviews

Responding publicly to negative reviews is usually good practice and shows other customers how problems are handled. Responses should be factual and polite and must not disclose personal data or confidential information, which is especially important for healthcare, legal and financial services bound by confidentiality duties.

Where a review appears fake, for example from someone with no record of being a customer, use the platform’s reporting process rather than posting accusations. This article is a general overview and not legal advice.

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