The Digital Markets, Competition and Consumers Act 2024 specifically outlaws fake and misleading consumer reviews. This law came into force in April 2025. The Competition and Markets Authority ("CMA") issued guidance to businesses on the new law in April 2025 and further insights into the CMA's approach to this topic are evident in undertakings that the CMA published in June 2025.
The CMA lists ensuring compliance with the new law on consumer reviews as a priority for 25/26. After feedback from business, the CMA allowed a three-month adjustment period – during April, May and June 2025 - when the CMA agreed to prioritise supporting businesses with their compliance efforts with the new law on consumer reviews rather than enforcement action.
The three-month enforcement hiatus concluded earlier this month, and the CMA has now completed a website review of more than 100 businesses. The review has focused on whether businesses have:
- published policies on their websites prohibiting fake reviews; and
- outlined how they approach incentivised reviews (such as banning them or making it clear that they must be labelled and genuine).
The CMA found that more than half of the businesses (54 in total) could be failing to comply with the CMA's guidance. Some companies appeared to have no policy in place banning fake reviews, nor could a policy be found setting out their approach to incentivised reviews. Others had policies in place, but they were unclear, incomplete or inaccessible.
The results have raised concerns over businesses' understanding of their obligations around the prevention of fake and misleading reviews – and the CMA is stepping in to address this. It is writing to those 54 firms highlighting that businesses must have measures in place to prevent fake reviews from appearing on their sites, including clear and easily accessible policies. The CMA is advising them to review the fake reviews guidance to see if further changes to their current approach and policies are needed. Any company that receives a letter is being asked to respond to the CMA explaining what changes, if any, they have made, or are making, to comply with the law.
The CMA now has hefty fining powers to punish non-compliance with the new law and can fine a trader up to 10% of annual global turnover. Given this, businesses involved in writing, procuring or publishing consumer reviews who have not already reviewed their practices and taken heed of the CMA guidance should do so sooner rather than later.
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