Fake reviews are now against the law in the UK: what the DMCC Act means for a small business

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, and the business that orders the review is caught by it alongside the person who types it. The practical answer for a small business has not changed; it has gained a legal floor. Do the work, ask real customers at the right moment, make it easy, respond to what comes back, and stop worrying about the number.

This is general information about the law as published, not legal advice. If you have a specific situation, ask a solicitor.

What does the DMCC Act actually say about reviews?

Paragraph 13 of Schedule 20 to the Act names three 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.

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.

Three separate acts, then: ordering or writing the review, publishing reviews misleadingly, and publishing without reasonable steps to keep fakes out. Most small businesses only ever touch the first. If you display reviews on your own website, the second and third apply to you too.

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 counts as reasonable steps will differ between a large platform and a trader publishing reviews from its own customers.

The word that matters for a small business is “commissioning”. The CMA says commissioning “can take many forms and is not limited to making monetary payments”, and gives asking a member of staff to write a review as an example. Its list of incentives includes money, commissions, 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. If you order the reviews, you commissioned 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”. A disclosure tucked behind a “learn more” link is one of the guidance’s own examples of concealment.

Google’s rule is stricter. Its Maps User Generated Content Policy says Google does not allow merchants or users to offer “incentives – such as payment, discounts, free goods and/or services - in exchange for posting any review”, and says prohibited content “will be removed”. So on Google a disclosed incentive is still a policy breach. The safe position for a Google review is simple: no reward, disclosed or otherwise.

What else does Google prohibit?

The same policy prohibits posting content on a competitor’s listing “to undermine that business’ or product’s reputation”, and prohibits merchants from discouraging or prohibiting negative reviews, or selectively soliciting positive reviews from customers. That last one 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. Google says it “may take actions” on violations, ranging from suspending account privileges to account termination.

How do I earn reviews properly?

Reviews are not something you buy. The CMA is explicit that asking is fine: emailing customers generally to ask if they wish to leave a review, “without predetermining the contents or sentiment expressed in the review”, is not prohibited. Four steps, in order.

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. For a framing workshop like AS Frames, that is when the customer collects the finished frame or the restored photo arrives in the post. For a barber, it is as the customer pays and looks in the mirror. Ask everyone the same way. 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. A QR code on the counter, a line in the completion text or email, a card in the parcel. The customer should never have to search for you to find the right place to write. The mechanics of this, including how to automate the ask after every job, are in our guide to getting more Google reviews without breaking the rules.

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. Replies are also part of a well-maintained Google Business Profile, which is where most of these reviews live.

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”, defines prominence as “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.

If you would like a hand doing this properly, our reviews service sets up the ask, the automation and the reply routine so it happens after every job without anyone remembering to do it. If you would rather see where your site stands first, the free Site Score takes about twenty seconds and needs no email address.

Reviews are the fourth of the five places a customer can find you. This article is one part of the whole-of-SEO video, “Not Who’s Best. Who’s Visible.”, which is coming soon; the companion page has the full outline and will carry the recording when it is published.