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UK Fake Reviews and Hidden Fees Ban: What Businesses Must Fix

Jun 15
6 min read

UK Fake reviews and hidden fees Ban: practices that are no longer just marketing problems. They are now direct legal and commercial risks for UK businesses.


The Digital Markets, Competition and Consumers Act 2024 strengthens consumer protection rules around misleading online reviews and hidden mandatory charges. This matters not only for large platforms, ticket sellers and online retailers. It can also affect small businesses, agencies, consultants, trades, service providers and online sellers.


If your business uses testimonials, Google reviews, Trustpilot reviews, “from £…” pricing, booking fees, admin charges or extra invoice items, you should check whether your marketing and sales process is clear enough. Poor wording can lead to consumer complaints, regulatory risk and unpaid invoice disputes.





UK Fake Reviews and Hidden Fees Ban

UK Fake Reviews and Hidden Fees Ban - What does the UK ban cover?

The UK rules are aimed at two common problems: fake reviews and hidden fees.

Fake reviews can include reviews that are not genuine, reviews written by people who have not used the product or service, reviews arranged by the business to create a false impression, or reviews that are manipulated to make the business look better than it really is.


Hidden fees are also known as drip pricing. This happens where a customer sees one price at the start, but mandatory charges are added later. Examples may include booking fees, admin fees, service charges, platform fees, installation fees or other unavoidable costs that were not made clear at the beginning.


The key point is simple: customers should not be misled about what they are buying, who they are buying from, what others genuinely think about the service, or what they will actually have to pay.


For background on fake reviews and the DMCC Act 2024, see our earlier article: Fake Reviews and the DMCC Act 2024: What UK Small Businesses Need to Know.

Why this is not just a problem for big online platforms

Many small businesses assume these rules only apply to large online platforms. That is risky.

A small business may still create legal problems if it uses misleading reviews, unclear prices or sales claims that do not match the service actually provided.


This can affect:


  • service businesses;

  • online shops;

  • marketing agencies;

  • consultants;

  • training providers;

  • subscription businesses;

  • trades and home improvement businesses;

  • professional services;

  • businesses using Google reviews, Trustpilot, testimonials or case studies.


The issue is not only whether the business intended to mislead someone. The practical question is whether the customer was given clear, accurate and timely information before deciding to buy.


If the customer only discovers important charges later, or if the business uses reviews that create a false impression, that can create legal and reputational risk.

Fake reviews: the marketing risk

Reviews are powerful because customers often trust them more than advertising. That is why fake reviews can be so damaging.


A business should be careful about:


  • buying reviews;

  • asking friends, family or staff to leave reviews without making the relationship clear;

  • offering incentives only for positive reviews;

  • removing or hiding genuine negative reviews;

  • using testimonials that are not based on real customer experiences;

  • copying reviews from another business or product;

  • presenting old or selective feedback in a misleading way.


Even where a business uses a third-party platform, it should still think carefully about how reviews are requested, displayed and used in marketing.


For more on reputation risk and misleading online review content, see: Fake Online Reviews and Business Reputation: Lessons from Davidoff v Google.

We have also written specifically about the risk of buying reviews on review platforms: Buy Reviews on Trustpilot: Legal Risk for Small and Medium Businesses.

Hidden fees and unclear pricing

Hidden fees can create serious problems because pricing is often the main reason a customer chooses one business over another.

The risk is highest where the business advertises a low headline price but later adds mandatory charges.


For example:


  • admin fees;

  • booking fees;

  • onboarding fees;

  • delivery fees;

  • installation charges;

  • cancellation charges;

  • compulsory service fees;

  • payment processing charges;

  • extra charges for work that was not properly explained.


Not every extra charge is automatically unlawful. The risk depends on how the price was presented, when the customer was told, whether the charge was optional or mandatory, and whether the customer clearly agreed to it.


A business can usually reduce risk by making mandatory charges clear at the earliest stage. If a fee is unavoidable, it should not be hidden until checkout, contract signature or invoice stage.

Why unclear sales promises can also create contract disputes

The legal risk is not limited to consumer enforcement. Unclear marketing can also create contract disputes.


Under section 50 of the Consumer Rights Act 2015, information said or written by a trader about the service may become binding if the consumer relies on it when deciding to enter into the contract or when making a decision about the service after the contract has been made.


This means website wording, emails, quotes, sales calls, brochures, testimonials and service descriptions can all matter.


For example, if a business says a service includes certain work, a certain timescale, a particular result or a particular level of support, the customer may later argue that this formed part of the contract. If the business then tries to charge more, deliver less or rely on small print that was not clear, a dispute can follow.


This is why marketing, terms and invoicing should not be treated as separate documents. They need to work together.

How poor processes lead to unpaid invoices

Many unpaid invoice disputes do not start with a customer simply refusing to pay. They start earlier.


Common problems include:


  • no clear written quote;

  • no agreed scope of work;

  • unclear service description;

  • vague “from” pricing;

  • no written approval for extra work;

  • hidden charges added late;

  • no cancellation policy;

  • no evidence that the customer accepted the terms;

  • marketing promises that do not match the invoice.


If a customer receives an invoice containing charges they say were never explained, they may dispute payment. They may argue that the price was unclear, the extra work was not authorised, or the business did not provide what was promised.


This can make debt recovery harder. It can also turn a simple unpaid invoice into a wider complaint about misleading pricing, poor communication or breach of consumer rights.


Good paperwork protects cash flow. A clear quote, clear terms, clear pricing and written approval for extras make it much easier to show what was agreed.

Practical checklist for businesses

Businesses should review their marketing and sales process before a dispute arises.


A practical compliance check should include:


  • Are all mandatory fees shown clearly before the customer commits?

  • Does the website explain what is included and what is not included?

  • Are “from £…” prices properly explained?

  • Are extra charges confirmed in writing before the work starts?

  • Are reviews genuine and based on real customer experiences?

  • Are incentives for reviews handled carefully and transparently?

  • Are negative reviews being handled fairly?

  • Do the terms and conditions match the sales process?

  • Does the invoice match the quote?

  • Is there evidence that the customer accepted the price and scope?

  • Are staff trained not to make promises the business cannot support?


Small changes can make a big difference. Often the problem is not one deliberately misleading statement. It is a messy process where the website, quote, terms, invoice and sales conversation all say slightly different things.

Call to action

If you are unsure whether your pricing, review policy, sales process or terms are legally safe, we can provide free initial advice.


We can review your website wording, service terms, invoices and customer process, and identify where unclear pricing or marketing claims may create consumer law risk, unpaid invoice disputes or reputational damage.


Getting the process checked early is usually cheaper than dealing with a complaint, chargeback, disputed invoice or legal claim later.

FAQs


Are fake reviews banned in the UK?

Yes, fake reviews can create legal risk for UK businesses. This includes buying reviews, arranging misleading reviews, using reviews from people who did not genuinely use the service, or presenting reviews in a way that creates a false impression. Businesses should make sure their review process is honest, transparent and properly monitored.


Are hidden fees illegal in the UK?

Hidden mandatory fees are risky. If a customer must pay a charge, the business should make that clear early in the buying process. Optional extras can usually be offered separately, but unavoidable fees should not be hidden until checkout, contract signature or invoice stage.


What is drip pricing?

Drip pricing is where a business advertises one price but adds extra charges later. The customer may only discover the real price after they have spent time going through the buying process. This can be misleading, especially where the extra charges are mandatory.


Can unclear pricing lead to unpaid invoices?

Yes. If the customer says they were not told about a charge, or did not agree to extra work, they may dispute the invoice. Clear quotes, written approval for extras and consistent terms make it easier to recover payment and defend the business position.


Why does Consumer Rights Act 2015 section 50 matter?

Section 50 matters because information said or written about a service may become part of the contract if the consumer relies on it. Website claims, sales emails, quotes and service descriptions can therefore become legally important. Businesses should make sure their marketing matches what they actually deliver.

 
 
 

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William Slivinsky PTech.NALP

 

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Email: william@businesslegaladvice.co.uk

business legal advicer william slivinsky 07946224674
Business legal advice provided by william slivinsky Membership No: 30244 national association of licensed paralegals

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Business Legal Advice is provided by William Slivinsky PTech.NALP, Membership No: 30244. Services are provided in accordance with the NALP Code of Conduct and Ethics for Members and focus on practical business legal support, unpaid invoice recovery, commercial debt recovery, payment disputes and contract-risk prevention. ICO Registration: ZB988076. NALP contact: admin@nationalparalegals.co.uk | 020 7112 8034 | nationalparalegals.co.uk

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