The Digital Markets, Competition and Consumers Act 2024 came into effect on 6 April 2025, imposing a ban on submitting or commissioning the publication of fake consumer reviews or concealing an incentivised review from consumers.
Incentivised Reviews
A consumer review conceals the fact it has been incentivised if:
- a person has been commissioned to submit or write the review; and
- that fact is not made apparent (whether through the content of the review or otherwise).
Incentives can take many forms under the rules and may include money, commissions, discounts and free product samples.
The new rules impose a ban on publishing consumer reviews in a misleading way which includes omitting relevant information, for example that a review has been commissioned.
Incentivising reviews is still permitted under the new rules, but it must be done in a way that is not misleading. Clear labelling of incentivised reviews is therefore required. Labelling can mean including wording at the bottom of the review to state “this review has been commissioned”, “incentivised review” or similar. Incentivised content creators and “influencers” must also clearly mark incentivised content as such.
Fake Reviews
Reviews of a product or service must represent a consumer’s genuine experience, or will be considered fake.
Reviews can take the form of text, speech, photos, videos and graphic representations, including a star rating. Aggregated ratings, review counts and rankings are also in scope.
Other banned practices include:
- publishing positive reviews but not negative ones;
- giving greater prominence to positive reviews; and
- excluding information relevant to the context of the review.
Next Steps for Businesses
Businesses must now act to take “reasonable and proportionate” steps to prevent and remove existing non-compliant or misleading reviews from their websites and other content. The Competition and Markets Authority (CMA) recommends a clear policy on the matter is implemented with processes put in place to identify any banned reviews. If any such reviews are identified they must promptly be removed.
The CMA has given retailers a short grace period until July 2025 to ensure practices are compliant. After this time the CMA will be taking enforcement action for non-compliance, including imposing fines.
Please get in touch if you would like further advice on how to ensure compliance with the new rules.
Madeleine Rhodes mrhodes@redfernlegal.com
