October 29, 2026 · 9 min read

UK fake review law: what a US business can learn from it

The UK fake review law bans fakes by statute, and Google agreed to sanction offenders. What it says and what it signals for US businesses.

The UK fake review law is not the rule that governs a US business, but it is worth reading anyway. The UK went further than the US in some places, and its regulator has already made Google change how it treats businesses that cheat. Those changes show where the rules are heading, and how a regulator reads habits that US rules also cover.

This post sticks to what the UK documents say and flags where I could not verify something. It is not a guide to UK compliance. If you sell to UK customers, ask a UK lawyer.

This is general information, not legal advice. Rules vary and change; talk to a lawyer about your own situation.

What the UK fake review law says

The ban sits in the Digital Markets, Competition and Consumers Act 2024. Schedule 20, paragraph 13 adds three things to the list of banned commercial practices:

• Submitting, or commissioning someone else to submit, a fake consumer review, or one that conceals the fact it was incentivised.
• Publishing reviews, or information drawn from reviews, in a misleading way.
• Publishing reviews without taking "such reasonable and proportionate steps as are necessary" to prevent and remove fake or misleading ones.

The Act defines a fake review as one that "purports to be, but is not, based on a person's genuine experience." That definition is short, and it does a lot of work. A review you wrote yourself fails it. So does one a friend wrote for you. So does a real customer's review that you paid them to rewrite.

The Competition and Markets Authority (CMA), the UK's competition and consumer regulator, published its fake reviews guidance (CMA208) on 4 April 2025. The provisions apply to commercial practices from 6 April 2025. The CMA's announcement on 7 April 2025 says it can now fine firms "up to 10% of their global turnover" for breaches of consumer law.

In the US, the FTC has to go to court for civil penalties. The CMA now enforces consumer law directly, which includes setting the fine itself.

The undertakings Google signed

Before the statute took effect, the CMA had spent years on a separate track. It opened enforcement cases against Amazon and Google in June 2021. The CMA's case page records that Google's undertaking was signed on 19 December 2024 and published on 24 January 2025.

An undertaking is a formal promise to a regulator, made in place of a finding of breach. Google's published commitments are specific:

Three details matter if you are trying to judge how far this reaches.

First, the scope is reviews and star ratings for businesses and services shown on Google Search and Google Maps. Product reviews are not covered.

Second, the business sanctions are fixed for three years. After that Google may change them, but they must stay escalatory, meaning they get tougher as the behavior gets worse or more frequent.

Third, Google said at the time that it planned to extend the sanctions to additional non-UK businesses, including EU businesses, by the end of 2025. I could not confirm that it did, and I found no statement on whether the sanctions apply to US businesses. Treat the extension as a stated intention, not a fact. For where US businesses stand today, read Google's own policy for Maps contributed content, which already applies to everyone. We walk through it in our Google review policy post.

What the CMA guidance names as a problem

The guidance is concrete, and several examples will look familiar from the US material.

Commissioning fake reviews. The CMA's examples include offering an existing customer a free or discounted product in exchange for a five-star review, and "contacting a customer who has left a negative review and offering them a refund and/or a gift card if they change their review to remove the negative commentary." The second one deserves a second look. Paying to change a real review is treated as commissioning a fake one. The US side of this is in our post on asking a customer to take a review down.

Suppressing negative reviews. Paragraph 4.4 says traders should not interfere with the willingness of reviewers to leave negative reviews. The examples include threats of harm or legal action, preventing real users from leaving reviews, "arbitrarily stopping and starting review invitations," and making an offer of dispute resolution depend on the customer not leaving a negative review.

Cherry-picking. Paragraph 4.5 says cherry-picking can happen "by encouraging just those who are satisfied to leave reviews." Read that again. In the UK guidance, asking only your happy customers is named as a way of misleading people. That is the practice usually called review gating. Our post on review gating and the FTC rule explains why the US position is less tidy but lands in a similar place once Google's own policy is added.

What is allowed. Paragraph 3.6 says that "merely emailing customers generally to ask if they wish to provide a review" is not prohibited. The distinction is between a general invitation and a predetermined outcome.

One more point from the guidance, because it surprises people. The CMA says it is "not prohibited per se" to publish an incentivised review. Paragraph 3.7 says a trader may offer payment or discounts for reviews if the review is clearly labeled as incentivised and still reflects the reviewer's genuine experience. That is the UK position under UK law, and it is not advice for a US business. Google's guidance for the profiles you manage calls incentives for reviews "strictly prohibited," so labeling does not rescue you there, and we do not recommend incentives in any form.

Enforcement so far

A new law means little until someone is investigated. Two things have happened.

The CMA's blog post of 17 April 2026 reports that it swept review publishers and sent advisory letters to 54 firms. The fines it mentions in that post relate to drip pricing, not reviews. I found no fine for a fake review yet.

On 27 March 2026 the CMA opened investigations into five businesses:

The CMA states that an investigation does not mean a breach has occurred, and that it has not concluded whether any of these businesses broke the law. Nothing here is a finding.

The mix is the useful part: hidden bad reviews, staff writing praise, a platform's rating math, discounts for stars. None involve a stranger selling reviews in bulk. They involve ordinary operating decisions.

What this means in the US

The UK law does not govern your US business just because it exists. I could not verify how far its reach extends to a US business with UK customers, and I am not going to guess. But three parts of the picture carry over without any legal stretch.

The US rule covers much of the same ground. The FTC's Consumer Review Rule, 16 CFR Part 465, took effect on 21 October 2024. It bans fake reviews, buying reviews, insider reviews without disclosure, and certain suppression tactics. In December 2025 the FTC sent warning letters to 10 companies about possible violations. Those letters are not findings, but they show the agency is looking. The FTC's letters cite the per-violation civil penalty maximum (90 FR 5580), and "per violation" can mean per review.

Platforms are the enforcement layer. The most practical consequence of the UK work is what happened on Google's side. A regulator reached an agreement, and the result was a warning label and a switched-off review function. That is faster and more damaging to a small business than a court case. Google's own tips for getting reviews and its policies already give it the power to act in the US. Our post on what to do when a profile is suspended covers how that plays out.

The line between asking and steering is the same. Both the UK guidance and the US material treat a general invitation to review as fine and a selective or rewarded one as a problem. The wording changes. The test does not.

The two systems side by side

Some cells are simplified. Read the linked documents before relying on any row.

The one practice that avoids all of this

The simplest way to stay clear of every rule above is to ask every customer, the same way, with the same link, and let the ratings fall where they fall. ReviewHero, for example, sends one email invitation to each customer you add, with the same Google review link for everyone, and applies no filter on how the customer feels. That is an example of a mechanism, not a sales point. You can do the same thing with a spreadsheet and a mail merge.

What cannot go in the process is anything that looks at the answer first.

What to do next

1. Read paragraphs 4.4 and 4.5 of the CMA guidance. They take ten minutes.
2. Look at how you invite reviews today. If any step depends on how the customer felt, remove it.
3. Delete any note or script that offers money, discounts, or gifts in connection with a review or a changed review.
4. If you have ever thanked staff for "getting five stars," stop. Ask them to invite every customer instead.
5. Write down one rule for your team: we ask everyone, and we do not ask anyone to change what they wrote.

Frequently asked questions

Is the UK fake review law in force? Yes. The consumer provisions of the DMCC Act, including the review ban, apply to commercial practices from 6 April 2025, according to the CMA guidance.

Did Google agree to sanction businesses with fake reviews? Google signed undertakings with the CMA. They commit it to put a warning on the profiles of UK businesses found boosting ratings with fake reviews and to switch off their review function, per the CMA announcement.

Does the UK law apply to my US business? I could not verify that. It depends on whether you target UK consumers, so ask a UK lawyer if you do.

Can the CMA fine a company for fake reviews? It can fine up to 10% of global turnover for consumer law breaches, per its April 2025 announcement. I found no fake-review fine so far.