Your opinion matters: the new rules on consumer reviews

Customer reviews can be a powerful marketing tool, which can help businesses improve their products and promote them to a wider audience. Care must be taken, however, that published reviews are not misleading. The publication of consumer reviews or consumer review information in a misleading way is now explicitly banned under new rules made under the Digital Markets, Competition and Consumers Act 2024, which came into effect on 6 April 2025.

The Competition and Markets Authority (CMA) has recently issued guidance for businesses to assist them in interpreting and applying the new rules. 

Key takeaways from the guidance include:

• A “consumer review” is “a review of a product, a trader or any other matter relevant to a transactional decision”. The review does not have to be written by a consumer, if it influences consumers’ decision making. For these purposes, a “consumer” is “an individual acting for purposes that are wholly or mainly outside that individual’s business”.
• “Consumer review information” is “information that is derived from, or is influenced by, consumer reviews” and includes aggregated information such as overall ratings and rankings. 
• The rules have wide application and cover not only those traders who publish reviews of their own products but also intermediaries such as social media platforms, specialist review sites and booking agents, who publish and/or collate reviews of other traders and their products.
• Consumer reviews in analogue form, for example a print publication or marketing letter, are also subject to the rules.
• Examples of publishing reviews in a misleading way include:
  • suppressing genuine negative or positive reviews
  • selectively promoting positive or negative reviews
  • omitting information about how reviews have been written
• Traders should not:
  • prevent reviewers from leaving negative reviews, for example by threatening legal action or making an offer of dispute resolution conditional on not leaving a negative review
  • limit access to and/or the impact of negative reviews by editing, withholding or removing such reviews
  • withhold relevant information about the circumstances in which reviews are written, for example where the reviewer has a financial interest in or commercial link with the trader or the trader’s products   
• Examples of publishing consumer review information in a misleading way include:
  • displaying a star rating or review count based on aggregation of reviews but failing to update it after non-genuine reviews have been identified and removed
  • allowing consumer review information to be determined or influenced by accepting commissions from traders in return for greater prominence in review rankings
• Traders must take reasonable and proportionate steps to prevent and remove misleading consumer reviews/review information. 
• All traders must:
  • publish a clear policy on the prevention and removal of misleading consumer reviews/review information
  • assess the risks of such material appearing on their media and take such further proactive steps as are reasonable and proportionate
• In particular, traders should put in place (and regularly review) procedures to:
  • detect misleading consumer reviews/review information
  • investigate misleading consumer reviews/review information
  • take action in response to misleading consumer reviews/review information

Breaches of the new rules will be punishable by a fine, imposed by a court or directly by the CMA. In theory, the maximum fine could amount to the higher of £300,000 or 10% of annual global turnover. The CMA has indicated however that there will be an initial grace period of 3 months (up to 6 July 2025) during which it will focus on supporting traders with compliance efforts, rather than enforcement.

The CMA guidance is available here. 

If you publish consumer reviews or consumer review information, you need to take reasonable and proportionate steps to prevent and remove fake reviews, concealed incentivised reviews and false or misleading consumer review information being published.

https://www.gov.uk/government/publications/fake-reviews-cma208/short-guide-for-businesses-publishing-consumer-reviews-and-complying-with-consumer-protection-law