Fake Reviews and the DMCC Act 2024: What UK Small Businesses Need to Know
- William Slivinsky
- 3 days ago
- 6 min read
Fake Reviews and the DMCC Act 2024
Fake reviews are no longer just a platform problem.
They are now a legal compliance issue.
Since 6 April 2025, the Digital Markets, Competition and Consumers Act 2024 has introduced specific rules dealing with fake reviews and misleading review information.
That matters for small and medium business owners because online reviews are part of the way customers decide whether to trust a business.
A customer may read reviews before visiting your website, calling you, booking a service, paying a deposit or buying from you.
That means reviews are not just comments sitting online.
They can influence the customer’s decision before the contract is even formed.
If those reviews are fake, manipulated or presented in a misleading way, the business creates legal risk.
I have written separately about why businesses should not buy fake reviews on Google Reviews, Amazon, Trustpilot, Facebook and TripAdvisor.
Fake Reviews and the DMCC Act 2024
Many businesses want quick trust.
They want more five-star reviews, stronger ratings and a better online image.
That is understandable.
For small businesses, online reputation can make a real difference. Reviews can affect enquiries, sales, bookings and customer confidence.
But buying reviews or arranging artificial feedback is not a safe way to build trust.
Fake reviews may make a business look better for a short time, but they create a weak legal foundation.
If a customer later complains, the business may struggle to stand behind the online message that helped persuade the customer to buy. Which may create and issue with Section 50 of the Consumer Rights Act 2015
A serious business should not manufacture trust.
It should structure it properly.
What changed under the DMCC Act 2024?
The Digital Markets, Competition and Consumers Act 2024 introduced specific rules about fake reviews.
The new rules are important because they deal directly with review practices that can mislead consumers.
The CMA guidance explains that the banned review practice covers three main areas:
fake reviews;
concealed incentivised reviews; and
publishing consumer reviews, or information derived from reviews, in a false or misleading way.
This means the issue is wider than simply writing a fake review yourself.
A business may create risk if it buys reviews, asks others to create artificial reviews, hides the fact that reviews were incentivised, presents ratings selectively, or uses review information in a way that gives customers a false impression.
Reasonable and proportionate steps
One of the most important phrases in the CMA guidance is “reasonable and proportionate steps”.
The guidance says traders who publish reviews should take reasonable and proportionate steps to prevent and remove fake reviews, concealed incentivised reviews and false or misleading review information.
This does not mean that every small business must operate like a large review platform.
But it does mean that a business should be able to show that it took sensible steps for the size and nature of the business.
For a small or medium business, that may include checking that reviews come from genuine customers, keeping records, avoiding pressure on customers, disclosing incentives and removing suspicious or misleading review material where appropriate.
The key point is simple.
If your business uses reviews to build trust, you should be able to explain why those reviews are genuine and fairly presented.
The risk is not only fake positive reviews
Fake reviews can work in two directions.
A business may use fake positive reviews to make itself look better than it really is.
But fake reviews can also be used against a business.
A competitor, unhappy customer or anonymous person may post false negative reviews to damage reputation, reduce enquiries and discourage customers from booking.
That is why fake reviews are bad for the whole market.
They distort trust.
They can give dishonest businesses an artificial advantage, and they can harm genuine businesses that are trying to compete properly.
This is why the issue matters not only for legal compliance, but also for honest competition.
Concealed incentivised reviews
One common risk area is incentivised reviews.
There is a difference between asking a genuine customer for honest feedback and encouraging a customer to leave a positive review in return for a benefit.
For example, a business may create risk if it offers a discount, voucher, free service or other reward in exchange for a review, but does not make that incentive clear.
The problem is stronger if the customer is encouraged to leave only a positive review.
A safer approach is to ask for honest feedback, whether positive or negative, and to disclose any incentive clearly.
The business should not make the review look like a completely independent customer opinion if the customer received something in return.
Misleading review information
The law is also concerned with misleading review information.
That can include the way reviews are selected, summarised or displayed.
For example, risk may arise where a business:
uses only selected five-star reviews;
hides negative feedback in a misleading way;
uses old reviews to suggest current quality;
claims “rated excellent” without a proper basis;
publishes star ratings without explaining the source;
uses testimonials that cannot be evidenced;
creates review summaries that give a false impression;
uses review badges or trust signals without checking what they actually mean.
The problem is not always the individual review.
Sometimes the problem is the overall impression created by the way the business presents reviews.
Reviews are part of the customer journey
A business should not treat reviews as separate from its legal structure.
Reviews, website wording, service descriptions, social media posts, customer messages, booking pages and terms and conditions all work together.
The customer may rely on several of those things before deciding to proceed.
That is why the online message must be controlled.
If your reviews say one thing, your website says another, and your terms try to limit everything later, the business creates uncertainty.
A proper legal structure should make sure that:
reviews are genuine;
website claims are accurate;
service descriptions match what is actually provided;
pricing is clear;
booking or order terms are presented before acceptance;
refund and cancellation terms are consistent;
customer communications do not overpromise;
evidence of what was agreed is kept.
This gives the customer a clearer position.
It also protects the business.
What small businesses should do now
If your business relies on online reviews, you should review your process.
Ask yourself:
Are the reviews genuine?
Can we connect reviews to real customers?
Are staff, friends or agencies leaving reviews as customers?
Are any incentives clearly disclosed?
Are customers being asked for honest feedback, not only positive feedback?
Are negative reviews being handled fairly?
Are review snippets on the website accurate?
Are ratings, badges and testimonials up to date?
Do our reviews match the actual service we provide?
Do we keep evidence behind our online claims?
This does not need to be complicated.
But it does need to be controlled.
A simple review compliance process
A small business should have a basic review process.
That may include:
asking genuine customers for honest feedback;
keeping customer records linked to reviews where possible;
not buying reviews;
not writing reviews for your own business;
not asking staff or family to pose as customers;
not using marketing agencies that promise fake review growth;
disclosing incentives clearly;
checking review widgets and testimonials;
removing or correcting misleading review information;
keeping screenshots and records where reviews are used in marketing.
The purpose is not to weaken your marketing.
The purpose is to make your marketing safer.
A business can still promote itself strongly, but the promotion must be genuine and evidenced.
What if your business is facing fake reviews?
If your business is facing malicious fake reviews, do not respond only with frustration.
Preserve the evidence first.
Take screenshots. Save the wording. Record the platform, date, profile name and visible account information.
Check whether the reviewer was a real customer.
Look at the pattern.
Are there repeated phrases?
Were several reviews posted close together?
Do the accounts look new?
Do they use names you cannot match to customer records?
Have enquiries, bookings or sales dropped after the reviews appeared?
The legal position depends on evidence.
Fake review cases are not won by suspicion alone.
You need a structured evidence trail before deciding what steps may be available.
Final point: do not manufacture trust
Buying fake reviews manufactures trust.
Proper legal structure builds trust.
A serious business does not need false reviews to persuade customers. It needs genuine feedback, accurate wording, clear service descriptions, controlled customer communications and properly drafted terms.
That creates a stronger position for both the customer and the business.
The customer understands what they are buying.
The business understands what it is promising.
That is real protection.
Need help with fake reviews or online review compliance?
If your business relies on Google Reviews, Trustpilot, Amazon, Facebook, TripAdvisor or other review platforms, your online reputation should not sit outside your legal structure.
I help small and medium business owners review their online claims, review wording, website wording, customer communications and terms so the legal position supports the way the business actually sells.
If your business is facing fake reviews, false online comments or concerns about review compliance, consider reaching out to me.
I can help you look at the evidence, understand the risks and decide what practical steps may be available.
Your online reputation is part of your business structure.
It should be protected properly.
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