CMA begins to take action on Fake Reviews

New rules which aim to crack down on the problem of fake or misleading reviews online came into force back in April 2025, as part of the phased implementation of the Digital Markets, Competition and Consumers Act 2024 (the DMCCA). The rules crucially include a requirement for certain companies to have a publicly accessible consumer reviews policy, if they either publish consumer reviews, or publish any collated third party rating/score based on customer reviews (e.g. a TrustPilot score). 

The consumer reviews policy will need to include a prohibition on fake or misleading reviews - which includes incentivised reviews (e.g. from influencers or employees) which are not clearly labelled, as well as setting out the company's approach to managing and preventing such reviews.

The Competition & Markets Authority (CMA) - the body responsible for enforcement - allowed a three-month grace period for companies to get these policies in place. Now that grace period has expired, action is being taken. In its latest update the CMA has announced that it has reviewed more than 100 businesses to check for compliance. Over half (54) of the businesses reviewed failed to comply with the new requirement and are being contacted by the CMA to explain the steps they are taking to rectify the non-compliance. 

Addressing fake reviews was always stated to be one of the key areas of focus for the CMA and it is clearly now putting that into practice. Putting in place proportionate procedures, as well as crafting an appropriate policy, should now be a priority for any businesses who publish reviews or use collated third party review scores as part of their marketing. If you require any assistance with this, please do get in touch with your usual Bristows contact.