Fake Reviews and Hidden Incentives: What the CMA’s Guidance Under the Digital Markets, Competition and Consumers Act 2024 Says Is Banned, From Star Ratings to Vouchers for Reviews

The unfair commercial practices provisions of the Digital Markets, Competition and Consumers Act 2024 (the DMCC Act) came into force on 6 April 2025. The Competition and Markets Authority (CMA) says the Act includes an explicit ban on the posting and commissioning of fake reviews, added to the banned practices list. This guide explains the vocabulary the CMA uses in its fake reviews guidance (CMA208, dated 4 April 2025) and what each term covers. The guidance does not name any nation, so none is assumed here. It is general information, not legal advice. The pages were read on 25 October 2026.

Four terms worth knowing

Fake review. The CMA defines it as a consumer review that purports to be, but is not, based on a person’s genuine experience. It can be positive or negative: a fake negative review is often written to undermine a product or trader.

Concealed incentivised review. A review is one if a person was commissioned to provide it and that fact is not made apparent, including through missing, obscure or hidden disclosure.

Consumer review information. Information derived from or influenced by reviews. The CMA gives overall ratings, overall summaries, review counts and rankings as examples.

Catalogue abuse. Sometimes called review hijacking or review merging: presenting reviews of a different product as relating to the product a shopper is considering.

What counts as an incentive?

The CMA says commissioning is not limited to money. Examples it lists of what a reviewer might be offered in exchange for a review include:

  • money or commissions
  • discounts or vouchers
  • leases or loans free of charge or on more favourable terms than the general public
  • products given free of charge
  • free stays
  • invitations to events

A footnote adds that offering a chance to earn a reward with no guaranteed direct benefit, such as entry into a prize draw, is unlikely to amount to commissioning.

Examples of conduct the CMA treats as banned

The guidance gives worked examples, including:

  • offering an existing customer a free or discounted product in exchange for a five-star review that does not reflect their genuine experience;
  • contacting a customer who left a negative review and offering a refund or gift card if they change their review so that it no longer reflects their genuine experience;
  • asking consumers to buy items with their own money and telling them they will be reimbursed once they submit a positive review;
  • buying reviews that look as if individual consumers wrote them but were generated by software such as bots;
  • offering traders a service that sets up and runs social media groups to recruit people to post fake reviews.

What is not a fake review

The CMA says a review is not fake just because the trader it concerns dislikes or disagrees with it, as long as it reflects the reviewer’s genuine experience. A review of a gift bought by a friend, or of a hotel stay cut short because the reviewer felt unsafe, can still be genuine.

Incentivised reviews are not banned outright. The CMA says that where they are permitted on a platform, they must be clearly identifiable as incentivised and still reflect the reviewer’s genuine experience. It adds that many platforms do not allow incentivised reviews at all, and that in those cases submitting one is likely to be misleading.

Star ratings and rankings

The ban reaches the numbers as well as the comments. The CMA gives two examples of publishing review information in a misleading way: showing a star rating or review count based on aggregated reviews without addressing the effect of fake reviews, for instance by not promptly updating the rating after reviews are removed as fake; and letting rankings be influenced by accepting commissions from the traders being reviewed in return for greater prominence.

It also says a trader may infringe the law by suppressing genuine reviews or selectively promoting positive or negative ones. Its examples of interfering with negative reviews include making an offer of dispute resolution depend on a consumer not leaving a negative review.

Who has to act, and what the guidance does not do

Traders who publish reviews must take reasonable and proportionate steps to prevent and remove banned reviews and false or misleading review information. The CMA says all publishers need a clear policy and a risk assessment. It also says that where banned reviews are being shown to consumers, that may indicate the publisher is not taking those steps.

The guidance is addressed to businesses: GOV.UK describes it as showing how businesses should comply with consumer protection law on reviews. It is not a shopper’s guide to spotting fakes. It notes that some conduct may also breach other law, for example the Fraud Act 2006 or the Advertising Standards Authority’s codes. The site’s guides to online shopping scams and to counterfeit goods on marketplaces cover other checks.

The bottom line

The CMA’s guidance covers fake reviews, concealed incentivised reviews and misleading ways of publishing reviews and review information such as ratings and rankings. It treats incentives broadly, from vouchers to free stays, allows incentivised reviews only where the incentive is clearly shown, and puts duties on the traders that publish reviews.

Sources

  • Fake reviews (CMA208), Competition and Markets Authority, 4 April 2025 (gov.uk)
  • Reviews and social media endorsements: guidance for businesses and brands, Competition and Markets Authority, last updated 28 August 2025 (gov.uk)
  • CMA to boost consumer and business confidence as new consumer protection regime comes into force, Competition and Markets Authority, 7 April 2025 (gov.uk)