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The UK Competition and Markets Authority (CMA) has opened five consumer law investigations into fake and misleading online reviews. Alongside a separate investigation into Adobe for its early cancellation fees, these new cases signal a change in CMA focus towards direct enforcement action, taking the view that business have had long enough to bring their practices into compliance.
Array of sectors and key review stages under investigation
Since April 2025, several practices relating to online reviews have been classified as "banned practices" under the Digital Markets, Competition and Consumers Act (DMCC Act), including posting fake reviews, publishing undisclosed incentivised reviews, hiding negative reviews, and presenting misleading star ratings.
The CMA is now investigating the conduct of five companies, bringing the total number of business being scrutinised by the CMA using its strengthened enforcement powers to 14. The five companies' activities span a variety of sectors:
| Sector | Suspected infringement |
|---|---|
|
Car sales |
Treatment of negative reviews: Whether one-star reviews were not published on Autotrader's platform and were excluded from star rating calculations |
|
Review platforms |
Treatment of negative reviews: Linked to the Autotrader investigation, as ratings were moderated by Feefo |
|
Funerals |
Misleading reviews: Whether staff were asked to write positive reviews about Dignity's crematoria services |
|
Food delivery |
Star ratings: Whether a food delivery platform's ratings system inflated certain restaurants' and grocers' star ratings |
|
Food delivery |
Discounts for reviews: Whether Pasta Evangelists' customers were offered discounts on future orders in exchange for leaving five-star reviews on delivery apps, without disclosure |
The CMA will now collect further evidence from each of the companies to decide whether it has reasonable grounds to suspect a breach of the consumer protection rules. The CMA anticipates releasing case updates in September 2026, but there is no legal deadline to make this decision.
At this initial stage, there is no assumption that any of the companies have infringed consumer protection law. Ultimately, however, if an infringement is established, the CMA may impose fines of up to 10% of annual global turnover.
Key enforcement takeaways
1. It is not only clearly fabricated reviews which are at risk.
The CMA is targeting the full online reviews ecosystem, examining incentivised review solicitation, staff-written reviews, suppression of negative reviews, and inflation of star ratings. By taking cases across each of these stages, the CMA is investigating multiple practices that can shape what people see when they search, shop or book online.
2. The CMA is picking cases to encourage compliance in crucial consumer-facing industries.
Concerned about the impact of cost-of-living pressures, the CMA is seeking to prevent harm in areas of essential spend (car sales) and at moments of vulnerability (funerals).
3. The CMA's focus has switched from compliance guidance to direct enforcement.
Like the eight online selling practices cases launched in November 2025, these latest investigations follow the CMA's "process in action" approach described in a recent speech. During 2025, the CMA initially took steps to support companies' compliance: it issued guidance on fake reviews, conducted a web sweep of over 100 review publishers, sent advisory letters to 54 firms, and ran a webinar. It states that this new programme of work on fake reviews "marks the next phase." Clearly, the CMA's window for voluntary compliance has narrowed, and all businesses should take note.
Top tips for businesses
On announcing the new investigations, CMA chief executive Sarah Cardell declared that "Fake reviews strike at the heart of consumer trust" and noted that the CMA has "given businesses the time to get things right."
We have already seen the CMA issue its first fine under its direct consumer enforcement powers, for procedural non-compliance. As the CMA continues to monitor compliance through sector-website sweeps, fines and conduct requirements are now firmly on the cards for breaches of consumer law, especially where practices are particularly egregious.
Compliance should be a priority for all businesses that publish online consumer reviews. We set out below our three top tips:
- Take reasonable and proportionate steps to prevent and remove fake reviews, including: (i) publishing a policy that clearly prohibits fake reviews and sets out the business's approach to incentivised reviews; (ii) completing a risk assessment of the likelihood of banned content appearing on the platform; and (iii) designing processes to detect, investigate and act against banned reviews and misleading review information.
- Do not rely on outsourcing review moderation to a third party as a defence. Remember that businesses remain individually responsible for preventing and removing banned content.
- Familiarise digital and marketing teams with the CMA's guidance on when consumer reviews are unlawful. A short, practical guide on businesses' obligations is available online alongside the CMA's detailed guidelines.
The content of this article is intended to provide a general guide to the subject matter. Specialist advice should be sought about your specific circumstances.
