Online reviews shape billions of pounds of purchasing decisions every year. In April 2025, several practices relating to online reviews became 'banned practices' under the Digital Markets, Competition and Consumers Act 2024 (DMCC Act), meaning they are automatically deemed unfair and illegal. In this article, we summarise the CMA's enforcement activity and what businesses should do to protect themselves.
Enforcement in action
The CMA has already moved from guidance to enforcement. In January 2025, Google signed undertakings committing to enhanced processes to tackle fake reviews and sanctions to deter businesses that benefit from them.
The CMA has also swept more than 100 review publishers. It issued advisory letters to 54 firms – 90% made changes in response, and 75% said they better understood the rules.
Now, the CMA has launched five new consumer law investigations as part of a crackdown on fake and misleading reviews. The investigations cover a range of alleged conduct, including:
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misleading reviews, including whether reviews and star ratings are genuine and not inflated
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incentivised reviews, through use of discounts or money off in exchange for writing a review.
The CMA is examining the key stages of the online reviews ecosystem, from how reviews are obtained to how they are moderated and displayed. It is also looking at the star ratings that consumers rely on.
In our experience
CMA consumer law investigations typically begin after extensive information gathering has already been carried out by the CMA over several months. They then issue an Information Notice, using statutory powers to require businesses to produce information and answer written questions. These requests can be wide‑ranging, covering internal communications, compliance policies, technical systems, and commercial arrangements, and the process is often more burdensome than businesses anticipate. Although the CMA has direct enforcement powers under the DMCC Act, undertakings remain available as a route to resolution. Where a business engages constructively and demonstrates a genuine commitment to compliance, the CMA may still seek binding commitments to change behaviour rather than proceed to a formal infringement decision, as it did with Google.
If the CMA does decide to press forward, it will issue a Provisional Infringement Notice (PIN) before making any final finding, giving the business an opportunity to respond.
We have experience advising businesses through CMA investigations in the consumer protection space, including in relation to online reviews. In our experience, the businesses best placed to defend themselves are those that can demonstrate robust policies and processes were in place before the investigation began. Critically, the CMA increasingly scrutinises not just whether a policy exists, but whether it was being implemented effectively in practice.
Papering your compliance
The CMA's recent action has brought its prioritisation of this area into sharp focus. Even if you're not currently under investigation, now is the time to review your compliance position.
All publishers of consumer reviews must have a clear policy on the prevention and removal of banned reviews and false or misleading consumer review information. If you already have a policy in place, you should assess whether your existing systems and processes achieve that purpose, and whether they need to be enhanced.
A compliant published policy should:
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set out your approach to incentivised reviews. If they are not permitted, say so. If they are permitted, make it clear that any incentives must be apparent from the review itself or otherwise clearly disclosed. Concealed incentivised reviews must be prohibited in all cases. Make it clear what is and isn't permitted where users have any control over how reviews and ratings are displayed.
Policies should be readily accessible and should not be buried in small print or a hard-to-find corner of your website. They should be signposted from the relevant parts of your platform.
Beyond the policy itself, publishers should have systems and processes in place covering at a minimum:
Act now
Fake reviews are no longer just a reputational risk. If the CMA finds an infringement of the law, it can require businesses to change their practices and impose fines of up to 10% of global turnover. Whether you run a review platform, commission marketing content, or display customer ratings on your website, you should review your policies now.
The CMA expects to provide an update on the new investigations in September 2026.
For a concise overview of what the CMA's new rules cover, see our fake reviews flyer. For details on how the rules affect influencers and affiliate marketing, see our article: How the DMCC Act affects influencer and affiliate marketing.
