CMA launches first investigations into fake and misleading reviews

The CMA has today launched five new consumer law investigations into potential fake or misleading reviews, spanning a wide range of sectors, including car sales, food delivery and funerals. The investigations mark the next stage in the CMA's work to improve consumer trust and transparency in the online sector by preventing fake and misleading reviews.

The CMA also carried out a website review of more than 100 businesses in order to check whether they have the necessary published policies in place that prohibit fake reviews and set out their approach to incentivised reviews. The review highlighted that more than half of these businesses may be failing to comply with these requirements and the CMA has sent 54 letters highlighting the need for all businesses to have these measures in place in order to comply with the legislation. Anyone who receives such a letter from the CMA will have to review and where necessary amend their practices and respond to the CMA explaining what changes they have made to comply.

The CMA's press release announcing the investigations also contains helpful top tips for consumers on how to spot some of the warning signs that online reviews may not be genuine reviews.

Consumer protection and fake reviews

The prohibition against fake and misleading consumer reviews was introduced under the Digital Markets Competition and Consumers Act (DMCC Act) as part of a number of substantive changes to the UK consumer protection regime, aimed at improving and modernising consumer rights to ensure they keep pace with market developments, in particular the trend towards online retail and advertising. 

It came into force on 6 April 2026. However, the CMA recognised that the new provisions around fake reviews required a number of changes to businesses' systems and compliance programmes, and on that basis it committed to focus on supporting businesses with their compliance work for the first three months rather than on enforcement. The CMA's investigations launched today now make it clear that the CMA has moved on to the next stage in its enforcement policy and that fake reviews are a clear enforcement priority.

The prohibition is widely defined and consists of a range of practices including submitting or commissioning fake consumer reviews or reviews that conceal the fact that they have been incentivised. It also includes publishing fake consumer reviews or consumer review information in a misleading way, and businesses that publish or provide access to reviews have a legal responsibility to ensure that consumers are not misled by the information from the reviews they present to consumers.

Failing to take reasonable and proportionate steps to prevent and remove from publication banned reviews and false or misleading consumer review information is also an infringement of the banned practice. This creates a positive obligation, requiring all businesses who publish consumer reviews or consumer review information to take effective action to comply with the law. It includes a requirement for a published policy that clearly prohibits fake reviews and confirms the publisher's approach to incentivised reviews and consumer review information. Publishers must also carry out regular risk assessments and put in place processes to assist with the detection of banned reviews, the removal of such content and the risk of it reappearing.

The CMA has published guidance on fake reviews that clarifies the key concepts of the banned practice and a separate short guide for businesses who publish consumer reviews or consumer review information.

The CMA's investigations

The CMA is investigating five businesses over concerns that they may not be complying with the requirements imposed on businesses in order to avoid fake or misleading reviews. The investigations are at an early stage and it should not be assumed that any of the businesses under investigation have infringed the law. Once the investigations are completed the CMA's decisions will provide helpful clarification around the prohibition of fake reviews, in addition to its published guidance.

Autotrader investigation

The CMA is investigating whether a number of 1-star reviews were not published on Autotrader's platform and were not counted towards its star ratings, thereby failing to present a complete representation of its customer's experiences.

The CMA's guidance on fake reviews makes it clear that 'a trader may infringe the law if they suppress genuine negative or positive reviews, selectively promote positive or negative reviews or omit information around how reviews have been written'.

Feefo investigation

The CMA's investigation in this case is linked to its investigation into Autotrader, as Autotrader's star ratings were moderated by Feefo.

Pasta Evangelists investigation

The CMA is investigating whether customers were offered discounts on future orders in exchange for leaving 5-star reviews on delivery apps, without this being disclosed.

The CMA's guidance on fake reviews flags that whereas it is permitted to post incentivised reviews, the review should be clearly identifiable as incentivised.

Just Eat investigation

The CMA is investigating whether Just Eat's ratings system has inflated the star ratings for certain restaurants and grocers.

Dignity investigation

The CMA is investigating whether Dignity asked its staff to write positive reviews about its services, thereby giving customers a potentially inaccurate picture of genuine customer feedback.

The CMA's guidance lists 'omitting information relevant to how reviews have been written' as a possible indication that consumer reviews have been published in a misleading way. This includes a situation where the reviewer has a financial interest in the trader or the product being reviewed (for example is an employee or shareholder of the trader) or has a commercial link with the trader.

Comment

The latest investigations bring the total number of businesses under investigation under the CMA's new enhanced consumer powers to fourteen. In November 2025 the CMA launched its first investigations under the new regime into eight businesses, focusing on online pricing practices, including drip pricing and pressure selling (see our blog post here). On 19 March 2026 the CMA opened an investigation into Adobe's conduct over concerns that early cancellation fees on membership plans for certain products may breach consumer protection law. 

Consumer facing businesses should be on alert that the CMA will not hesitate to use its enhanced consumer protection enforcement powers across a wide range of sectors and practices. It is proactively monitoring businesses' websites for compliance and has also published guidance on how to make a consumer law complaint, which can be expected to increase the risk of detection of non-compliance. Businesses should therefore make sure they are fully prepared by identifying the key risk areas for their business and putting in place the necessary processes and compliance measures. Failure to do so may result in breaches of consumer legislation which can incur fines of up to 10% of the businesses global annual turnover.