CMA fake reviews guidance: reviews that look genuine

The rule

Since 6 April 2025 fake reviews have been a banned practice in the UK, not a matter for a case-by-case fairness test. The banned practices sit in Schedule 20 of the Digital Markets, Competition and Consumers Act 2024 (DMCCA), which section 225 brings into the general prohibition on unfair commercial practices. Section 225(4) lists Schedule 20 practices, “commercial practices which are in all circumstances considered unfair”, among those the Act prohibits.

The wording turns on what a review purports to be. It does not turn on who runs the site. It reaches the trader who writes or buys a review, the agency that arranges it, and the business that publishes reviews written by others. The Schedule 20 provisions came into force on 6 April 2025 under SI 2025/272.

The CMA does not need a court to decide these cases. Its press release on the Amazon undertakings says that under the DMCCA the CMA can itself decide whether consumer law has been broken and impose fines of up to 10% of global turnover, without going through the courts.

What PeekWell checks and how

UK-13 reads the reviews and testimonials a visitor can see on a public page and asks two things. Does the page say whether and how they were checked? Do any of them look possibly fabricated?

The scan is automated. It finds the reviews and testimonials on your public pages and looks for a statement about how they were collected or checked. A page with reviews and no such statement is recorded as observed that way.

The second answer is a flag, not a fact. The scan looks for signs a review may not be genuine, such as the same wording across several reviews or a photo that also turns up elsewhere. Anything like that is reported as possibly fabricated and worth a second look. It never says a review is fake. A real customer may have had help with the wording or reused a picture.

The check is the same as EU-11 and US-01. Only the rule it’s read against changes.

The scan has limits, and the report says so. It sees the public pages it visited, and the members area when you give it a sign-in. It doesn’t contact reviewers, check reviews against your orders, or see what your review service held back. It doesn’t read your agency contracts, so it can’t tell whether a review was commissioned or incentivised. The Act’s incentive wording needs knowledge of how the review came about, and the scan has none. A Passed means the expected behaviour was observed on the pages scanned. It doesn’t say the site complies.

Why it matters for a company

The CMA has used its review powers in three ways, and each applies to a different kind of business.

It has taken undertakings from large platforms. Google offered changes in January 2025, and Amazon followed in June 2025. Amazon’s undertakings commit it to systems for detecting and removing fake reviews and “catalogue abuse”, where reviews of a well-performing product are moved to a different one, and to sanctions that can include a ban from selling. These were undertakings given after investigation, with no fine in either case.

It has also opened cases under the new regime. On 27 March 2026 it announced investigations into five businesses, opened the day before. Autotrader and Feefo are examined over whether moderated 1-star reviews were not published or counted towards star ratings. Dignity is examined over whether it asked staff to write positive reviews. Just Eat is examined over star ratings that may have been inflated. Pasta Evangelists is examined over discounts offered for 5-star reviews on delivery apps. The CMA’s case pages say that “it should not be assumed” that any of them has infringed and “no finding has been made”.

Finally, it has written to publishers. The CMA says it swept more than 100 review publishers and sent advisory letters to 54.

For a company, the cases suggest where review problems tend to come from: how reviews are collected, which ones are published, and what staff or agencies were asked to do. The statement of how reviews are checked is where a regulator or a reader first looks.

Smaller companies and larger companies

The ban has no size threshold. The standard for hosts, reasonable and proportionate steps, scales with what a business can do, but the ban on writing or commissioning fake reviews applies to everyone.

In a small business the risk is usually informal. A founder asks friends and family to post a few 5-star reviews at launch. A freelancer is briefed to “get the Google rating up”. A shop offers a discount code in exchange for a review and the review does not say so. Staff post under their own names without saying who they work for. None of this is hidden on purpose. The page simply carries it with no label. The CMA’s Pasta Evangelists case concerns this kind of arrangement, offered at a discount in exchange for 5-star ratings, though it is an open investigation and not a finding.

In a larger business the same behaviour arrives through process. Review invitations are sent only to customers likely to be happy. An agency runs a seeding programme. Moderation rules sit with a vendor, and no one can say why some 1-star reviews never appear. The Autotrader and Feefo investigation is about that gap between the business, its vendor and what the public sees.

How to fix it

These steps are practical, not legal advice.

1. Find every review and testimonial on your pages. Include product pages, landing pages, case studies and ad images. Write down where each came from.
2. Take down anything you cannot trace to a real customer. A quote you wrote yourself, or that an agency supplied, should not be shown as a customer’s experience.
3. Label testimonials. If you choose praise to show, mark it as testimonials, as the CMA’s guidance describes. Do not show a hand-picked set as if it were all your reviews.
4. Disclose incentives in the review. If a reviewer got a discount, a free product or payment, the review should make that apparent. Do not make any reward depend on a positive rating.
5. Publish negative reviews too. Ask your review service how it moderates, and whether 1-star reviews are held, delayed or left out of the average. Adjust the settings so the same rules apply to every review.
6. Write it down for agencies and staff. Contracts and briefs should rule out fake or concealed-incentive reviews. Tell staff not to post about the business without saying who they are.
7. Say how reviews are collected and checked. Put a short note next to the reviews, in the same place a visitor reads them.
8. Re-scan. Run a scan again. The note should now be found, and flagged items should be gone or explained.