CMA steps up its crackdown on fake and misleading reviews

On 27 March 2026 the Competition and Markets Authority (CMA) announced that it had opened a series of new investigations into fake and misleading reviews under the Digital Markets, Competition and Consumers Act 2024 (DMCCA).

The CMA has been trailing this issue as an enforcement priority for a long time. Back in July 2025 it issued 54 advisory letters in relation to fake reviews, and it also agreed undertakings with Amazon and Google last year following investigations that were launched under the old pre-DMCCA regime.

These are the first formal fake reviews cases brought under the DMCCA. The CMA has the power to impose penalties up to 10% of global turnover in each case.

What kind of review practices is the CMA investigating?

The CMA is looking into a number of alleged practices, ranging from suppression of negative reviews to offering incentives in return for 5-star reviews and asking staff to write fake positive reviews.

The table below gives a summary of the parties involved and what the CMA is investigating in each case. All investigations are ongoing and the opening of a CMA investigation does not prejudge any finding of wrongdoing.

Why this matters for consumer-facing brands

These cases confirm that the rules on fake and misleading reviews don’t just apply to large platforms.

As the Pasta Evangelists case shows, brands can find themselves in hot water even if they don’t actually host reviews on their own site – for example if they offer incentives for positive/ 5-star reviews on third party apps or platforms.

In Dignity’s case, staff are alleged to have been asked to leave positive reviews of the brand’s services online. This is a risk that could potentially be relevant to thousands of businesses.

On the whole, they show that the CMA really means business when it comes to enforcing the new banned practice relating to fake and misleading reviews under the DMCCA. The CMA’s attention isn’t just focussed on the largest digital platforms and review sites – in other words, there is no ‘safe harbour’ when it comes to the risk of CMA enforcement in this area.

Risk mitigation

As the CMA’s guidance acknowledges, there is no ‘one-size-fits-all’ approach to compliance in this space.

For example, an online marketplace that hosts third-party reviews for thousands of merchants will have a very different risk profile to a brand that only hosts reviews of its own products on its website.

Either way, the CMA guidance is clear that the first step is a risk assessment. Step back and ask yourself what your risk exposure is as a brand to fake or misleading reviews (whether on your own website or third-party platforms). Are you doing enough to try and close loopholes? Are your policies clear?

And don’t forget, the rules don’t just prohibit outright ‘fake’ reviews. They also apply to:

• Concealed incentivised reviews. For example, if a review is left in return for a voucher or free gift, which is not disclosed. The need to disclose the existence of the incentive applies even if the review in question is ultimately genuine and honest. This reflects the CMA’s view that consumers should be able to distinguish between ‘organic’ reviews, and reviews that have been left because the reviewer received an incentive.

• Misleading consumer review information. For example, providing aggregated summaries of reviews that are misleading and don’t provide an accurate representation of the total reviews. Note that this also applies to AI-generated summaries of reviews if the LLM is not properly trained, for example if it is trained to skew positive and downplay negative reviews.

This publication is intended for general guidance and represents our understanding of the relevant law and practice as at March 2026. Specific advice should be sought for specific cases. For more information see our terms & conditions.