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Fake and incentivised reviews under the UK DMCCA 2024: banned practices, positive obligations, CMA enforcement, CAP Code and Online Safety Act interplay

Practice notes
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This Practice Note explores the deployment of consumer reviews (including fake reviews and concealed incentivised reviews) and their treatment as a banned unfair commercial practice under the Digital Markets, Competition and Consumers Act 2024 (DMCCA 2024). It also examines obligations set by the UK Code of Non-broadcast Advertising and Direct and Promotional Marketing (CAP Code).

Introduction

Consumer reviews are vitally important in guiding individuals on whether to purchase a product or obtain a service. When used appropriately and in line with the law, they deliver detailed insight into the authentic experiences of others and can be harnessed by businesses to demonstrate credibility and reliability to prospective customers alike. When misused, they may manipulate search rankings, mislead consumers about a product’s genuine efficacy, or otherwise create a deceptive overall impression that could influence a consumer’s transactional decision. Although reviews can appear both online and offline, the e-commerce sector has developed a pronounced dependence on reviews and rankings, including through online marketplaces designed to compare goods or even the businesses themselves. In 2015, the Competition and Markets Authority (CMA) estimated that as much as £23bn of UK consumer spending each year is potentially influenced by online reviews, with more recent studies finding...

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Web page updated on 21/05/2026

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