Fake And Incentivised Reviews

The Short Version

The CMA's guidance says three things are banned: fake reviews, reviews where an incentive such as payment or a free stay is not disclosed, and review information (such as star ratings, counts or rankings) based on fake reviews. Writing or commissioning fake reviews is prohibited.

Who It Applies To

Any business that publishes consumer reviews or information about reviews, whatever the source. That includes retailers' own sites, social media, search services, online marketplaces and specialist review sites. Third parties that provide access to reviews are also responsible. You can outsource monitoring, but you stay responsible for your own steps.

Reasonable And Proportionate Steps

The CMA does not set a single list. It says to weigh factors such as:

• the incentives and opportunities for fake content in your sector;
• where reviews come from, such as posted directly on your site or imported from another;
• whether your site has sharing or promotion features;
• the effect on the businesses being reviewed;
• the extra risk from aggregated ratings.

Practical Steps The CMA Lists

1. Publish a policy that clearly prohibits fake reviews and explains your approach to incentivised reviews.
2. Carry out a risk assessment, and repeat it regularly, especially before changes that could raise the risk.
3. Set up processes to detect and prevent banned content, investigate suspected cases and act on them, including by removing content.
4. Use evidence such as user concerns and internal investigations in your risk assessment.
5. Review how well your processes work and adapt to new threats.

Examples of sanctions in the short guide include clear warnings on pages and banning users.

Our product page checklist includes a short reviews section.

What We Do

SiteAudit looks for the information a customer can see about how your reviews are collected and checked, and flags missing or unclear information as a possible risk. We cannot see inside your review systems unless you ask us to include them.

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