Are fake reviews illegal in the UK? What the DMCC Act means for your business

Yes. Since 6 April 2025, buying a review, writing your own, or paying for a review that hides the payment has been against the law in the UK, not only against Google’s rules. The Digital Markets, Competition and Consumers Act 2024 added fake and concealed-incentivised reviews to the list of banned commercial practices, the business that orders a review is caught alongside the person who types it, and the CMA says it can fine a company that infringes consumer law “up to 10% of their global turnover”. The practical answer for a business has not changed; it has gained a legal floor. Do the work, ask real customers at the right moment, make it easy, and respond to what comes back.

This is general information about the law as published, not legal advice. If you have a specific situation, ask a solicitor. The practical side, how to ask and when, is in how to get more Google reviews without breaking the rules.

What does the DMCC Act actually say about reviews?

Paragraph 13 of Schedule 20 to the Act names four banned practices. Quoting the legislation:

• 13(1): “Submitting, or commissioning another person to submit or write, (a) a fake consumer review, or (b) a consumer review that conceals the fact it has been incentivised.”
• 13(2): “Publishing consumer reviews, or consumer review information, in a misleading way.”
• 13(3): “Publishing consumer reviews, or consumer review information, without taking such reasonable and proportionate steps as are necessary” to prevent the publication of fake reviews, reviews that conceal an incentive, and review information that is false or misleading, and to remove any such reviews or information from publication.
• 13(4): “Offering services to traders (a) for the doing of anything covered by sub-paragraph (1) or (2); (b) for the facilitating of anything covered by sub-paragraph (1) or (2) to be done.”

The Act defines a fake consumer review as one that “purports to be, but is not, based on a person’s genuine experience”. A review conceals the fact it has been incentivised where “a person has been commissioned to submit or write the review, and that fact is not made apparent”. Paragraph 13 came into force on 6 April 2025 under S.I. 2025/272.

Paragraph	What it bans	Who it catches
13(1)	Submitting or commissioning a fake review, or one that hides an incentive	The writer and the business that ordered it
13(2)	Publishing reviews in a misleading way	Anyone who displays reviews, your own website included
13(3)	Publishing reviews without reasonable steps to keep fakes out	Anyone who displays reviews, scaled to their role
13(4)	Offering traders a service that does 13(1) or 13(2)	The review-selling agency

Most businesses only ever touch the first. If you display reviews on your own website, the second and third apply to you too. The fourth is the one that catches the review-selling agency.

Who is covered?

Broadly, everyone in the chain. The CMA’s guidance on the ban says that “anyone who engages in the commercial practice of either submitting or commissioning banned reviews will be in breach”, and its list runs from professional reviewers and content creators to “marketing companies, individuals acting on behalf of traders”. It also says the duty to prevent and remove banned reviews “is non-delegable and applies to all traders who publish consumer reviews or consumer review information”, while noting that what is reasonable and proportionate varies with whether a trader is directly responsible for obtaining, verifying and managing the reviews.

The word that matters for a business is “commissioning”. The CMA says commissioning “can take many forms and is not limited to making monetary payments”, and gives a trader requesting a member of staff to write a review as an example. Its list of incentives includes money, discounts or vouchers, and products given free of charge. In a footnote it says a prize draw, where the reviewer is not guaranteed a direct benefit, is “unlikely to amount to commissioning”.

So the agency that offers to boost your Google rating is not taking the risk on your behalf. Its offer is itself a banned practice under 13(4). If you order the reviews, you commissioned them.

What can the CMA do about it?

More than it could before. The DMCC Act’s consumer protection provisions came into force on 6 April 2025, and the CMA’s announcement says the Act “includes an explicit ban on the posting and commissioning of fake reviews” and that “if a company infringes consumer protection law, the CMA can fine them up to 10% of their global turnover.” It also said that in its first year it would focus on behaviour “that is particularly harmful to consumers and represents clear infringements of the law”, while helping businesses understand what is expected of them.

Can I still reward a customer for a review?

Under the law, yes, but only if you say so. The CMA guidance is direct: traders “are free to” incentivise reviews, “but to comply with the law they must: (a) tell consumers that the review has been incentivised, and (b) the review must still reflect the reviewer’s genuine experience”. Where a platform allows incentivised reviews at all, the review “must be clearly identifiable as incentivised”, and the CMA says it will usually be necessary “at least to label the review prominently as incentivised, namely, as an advert”.

Google’s rule is stricter. Its Maps User Generated Content Policy prohibits offering incentives “such as payment, discounts, free goods and/or services - in exchange for posting any review”, and says fake engagement “is not allowed and will be removed”. The CMA guidance joins the two: where a platform does not allow incentivised reviews, “submitting an incentivised review is likely to be misleading”. So on Google a disclosed incentive is a policy breach and a legal risk too. The safe position for a Google review is simple: no reward, disclosed or otherwise.

What else does Google prohibit?

The same policy prohibits merchants from discouraging or prohibiting negative reviews, or “selectively solicit[ing] positive reviews from customers”, and prohibits content based on a conflict of interest, including current or former employment. Selective asking is review gating: asking the happy customers for a Google review and steering the unhappy ones to a private form. The CMA guidance treats it the same way, listing “encouraging just those who are satisfied to leave reviews” under cherry-picking, and making an offer of dispute resolution “contingent on a consumer not leaving a negative review” under suppression.

What if I show reviews on my own website?

Then 13(2) and 13(3) are yours as well. Quote reviews as written, do not pick only the glowing ones, and say what you have left out. Google’s review snippet guidelines, updated in July 2026, point the same way: “Don’t include fake or undisclosed incentivized reviews on your page or in your structured data markup.” Google also says a business that controls the reviews about itself is not eligible for star results on pages using LocalBusiness or Organization markup, so marking up your own reviews earns nothing.

On the site we built for AS Frames, a Leeds picture framer, which is ready and waiting to launch, the reviews page quotes 111 Google reviews as they were written, says which ones it leaves out and why, links to the full set on Google, and carries no review markup.

How do I earn reviews properly?

Reviews are not something you buy. The CMA is explicit that asking is fine: encouraging reviews “without predetermining the contents or sentiment expressed in the review, for example by merely emailing customers generally to ask if they wish to provide a review, is not prohibited”. We call the method that follows The Earned Review: four steps, in order, that make a review both lawful and useful to the next customer.

Do the work

A review is a record of what happened. If the job was good, the review can be good. If a repair shop like JorTech hands a phone back working, with the data intact, the honest review writes itself. No amount of asking fixes a bad job, and under the Act a review that says the job was good when it was not is a fake review by definition.

Ask at the right moment

Ask when the customer feels the value, not a fortnight later. Ask everyone the same way. For a framing workshop like AS Frames, that is when the customer collects the finished frame or the restored photo arrives. For a barber, it is as the customer pays and looks in the mirror. The moment you start choosing who to ask by how happy they look, you are gating.

Make it easy

One link, one tap, straight to the review form. The customer should never have to search for you to find the right place to write. A QR code on the counter, a line in the completion text or email, a card in the parcel.

Respond, every time

Thank the good ones by name and by detail. A reply that mentions the actual job tells the next reader that a real person is on the other end.

What should I do about a negative review?

Answer it in public, briefly, and take the conversation private. Do not turn your profile into an argument. Acknowledge the issue, say what you will do, and offer a direct way to sort it out. The next customer is reading your reply more carefully than the complaint.

Two things are now off the table. The CMA gives, as an example of commissioning a banned review, “contacting a customer who has left a negative review and offering them a refund and/or a gift card if they change their review to remove the negative commentary”. And a review is not fake “just because the trader who it is about does not like or agree with it, as long as it reflects the reviewer’s genuine experience”. If the review is genuinely fabricated, or from someone who was never a customer, report it through the platform and say plainly why. If it is merely unfair, reply well and move on.

Why is the count not the point?

Because nobody is counting the way you think. Google’s own page on local ranking says local results are “mainly based on relevance, distance and popularity”, heads the third factor “Prominence”, meaning “how well-known a business is”, and says that “more reviews and positive ratings can help your business’s local ranking”. Can. Reviews are one input among several, and Google publishes no threshold at which a business qualifies for anything.

The customer is not counting either. They are asking whether they can trust you, whether you have done this before, and what happened to the last person who walked in. A handful of specific, recent, honest reviews answers those questions. A wall of five-star one-liners posted in the same week does not, and it now invites the wrong kind of attention. A review is a piece of information another customer is reading, not an SEO object.

Reviews are the fourth of the five places a customer can find you. If you would like a hand doing this properly, the review ask, the replies and the profile around them are part of local SEO and Google Business Profile, quoted to your business: tell us what you need.