Reviews · 2026-08-21

Fake Google Reviews and UK Law: What the DMCCA Means for Your Business

The law changed — enforcement has started

The Digital Markets, Competition and Consumers Act 2024 (DMCCA) came into full effect on 6 April 2025. It replaced and strengthened previous consumer protection rules, giving the Competition and Markets Authority (CMA) direct powers to penalise unfair commercial practices without needing a court order first.

On 26–27 March 2026, the CMA launched its first formal investigations under the updated rules, targeting practices including discounts in exchange for five-star ratings and negative review suppression.

This is no longer a theoretical risk for small businesses. It is an active enforcement regime.

What is now banned

The DMCCA's Schedule 20 lists specific practices that are automatically unfair in all circumstances:

Submitting or commissioning fake reviews. Writing, arranging, or paying for reviews that do not reflect a genuine consumer experience is illegal.

Concealing incentivised reviews. Publishing reviews written in exchange for a benefit — discounts, free sessions, loyalty points, gifts — without a prominent disclosure label (such as #ad at the beginning of the text) is a banned practice. Google goes further: it prohibits incentives entirely, disclosure or not.

Review gating. Selectively publishing positive reviews while suppressing negative ones is unlawful under the DMCCA's automatically unfair and misleading-presentation rules. Filtering customer prompts based on expected sentiment — the "how was your experience?" funnel that only shows the Google link to happy customers — is classified as misleading presentation under the DMCCA.

The penalties

The CMA can issue direct fines of up to 10% of a business's global annual turnover or £300,000, whichever is higher. Individual directors face personal fines of up to £150,000 and potential disqualification.

For a small business turning over £500,000 a year, the maximum fine is £300,000 (the floor). For a multi-branch operation at £3 million, it is £300,000. At £5 million, 10% kicks in at £500,000. These are maximum penalties — actual fines will depend on the severity and scale of the breach — but the CMA has the power to impose them without a court hearing.

What Google bans separately

Google's Business Profile policies, updated in April 2026, add their own layer. Even if something is not explicitly illegal under UK law, violating Google's policies can result in review removal, loss of reply capabilities, or complete suspension of your Google Business Profile.

Google's April 2026 update specifically banned:

• Staff review quotas: Linking employee compensation to review collection numbers.
• Content direction: Asking customers to mention specific staff names, keywords, or service details. Google's automated systems may flag these patterns.
• On-premises solicitation: Shared tablets, kiosks, or review stations where customers leave reviews on-site.

Google's automated systems blocked 292 million policy-violating reviews in 2025. The detection is pattern-based: sudden volume spikes, IP clustering, and employee-name mentions are among the patterns Google scans for.

What is still allowed

You can ask every customer for a review, openly and equally, using the official Google review link, after they have experienced your service. The ask must be neutral — no star suggestion, no sentiment filter, no conditional language.

You must not treat happy and unhappy customers differently. If you use a post-visit survey before the review request, every respondent — regardless of score — must receive the same public Google review link.

Responding to negative reviews is not only allowed but recommended. A professional, calm response that acknowledges the issue and offers a resolution demonstrates accountability. You must never pressure a reviewer to change or remove their rating, and you must never make resolution conditional on review modification.

The publisher duty

Businesses that display reviews on their own websites are legally considered "publishers" under the DMCCA. They must take "reasonable and proportionate steps" to prevent fake or misleading reviews from being displayed. Outsourcing review collection to a third-party platform does not exempt a business from this liability.

If you embed Google or Trustpilot reviews on your website, you inherit a duty of care for the accuracy of what you display.

What to do now

1. Audit your current review solicitation. If you use a sentiment filter, funnel, or gating workflow — remove it. If you offer any incentive tied to reviews — stop.
2. Check your staff practices. If reception staff ask happy-looking customers for reviews while avoiding those who seem less satisfied, that is informal gating. Train all staff to make the same ask to every customer.
3. Review your displayed reviews. If your website selectively shows only positive reviews, that may constitute misleading presentation under the DMCCA.
4. Use the official link. Send customers the unmasked Google review URL, not a redirect or wrapper.

For a step-by-step compliant solicitation process, see how to ask customers for a Google review.