Guidance

Short guide for businesses: publishing consumer reviews and complying with consumer protection law

Published 4 April 2025

This summary is for businesses who publish consumer reviews or review information. It explains what you need to do to comply with your legal obligations.

There are other things businesses must not do (such as writing or commissioning others to write fake reviews). These are further explained in the full fake reviews guidance where you can also find lots of examples.

What fake reviews look like

Consumer reviews can take various forms. They might look like:

• text: for example, a written blog or a comment posted under a product listing on a website
• speech: for example, a verbal opinion expressed in a video on a sharing platform
• graphic representations: for example, a star rating appearing next to a restaurant’s name in search engine results, or a thumbs up next to a ‘helpful’ review

Information derived from or influenced by consumer reviews (consumer review information) is aggregated information in the form of overall ratings, review summaries, review counts and rankings.

It’s important that reviews and review information are trustworthy. There are several types of deceptive reviews and review information that consumers might see:

• fake reviews: these are reviews that look or claim to be genuine, but are actually fake
• concealed incentivised reviews: these are reviews that conceal the fact that they have been incentivised (for example, not making it clear that a review has been written in exchange for money or other benefits, like a free stay at a hotel or another ‘freebie’)
• false or misleading consumer review information: this includes aggregated information (when information is gathered from lots of individual reviews to give one overall score or rating) that is based on fake reviews

Who this guidance applies to

This guidance applies to you if you are a trader who:

• publishes consumer reviews or consumer review information, including about other traders and their products
• publishes consumer reviews or consumer review information from any source, including if you publish consumer reviews or consumer review information originally collated by someone else

You are responsible for any publication formats you operate. These might include:

• websites
• social media
• search services
• online marketplaces
• specialist review sites
• trader recommendation platforms
• print publications

Preventing and removing banned content

The law on fake reviews applies to all traders who publish consumer reviews or consumer review information. But what you need to do in practice depends on factors such as the source of the reviews, the volume of reviews you publish and the risk of fake reviews being contributed. 

Each individual trader who publishes reviews and review information is responsible for preventing and taking steps to remove banned content (namely fake reviews, concealed incentivised reviews and false or misleading consumer review information). 

If a third party also provides access to these reviews or information, they are also responsible and must take steps to comply with the law. 

You can make agreements with a third party to monitor reviews and information, but you are still responsible for taking your own steps to prevent and remove banned content.

Steps publishers need to take

If you publish consumer reviews or consumer review information, you need to take reasonable and proportionate steps to prevent and remove fake reviews, concealed incentivised reviews and false or misleading consumer review information being published.

You should make sure you have your own procedures for doing this. 

You should have a published policy that clearly prohibits fake reviews. Your policy should also state your approach to incentivised reviews and consumer review information.

In addition, there are several steps you will likely need to take to: 

• detect banned reviews and false / misleading consumer review information
• investigate banned reviews and false / misleading consumer review information
• take action in response to banned reviews and false / misleading consumer review information. This could include imposing sanctions where appropriate (for example, putting clear warnings on pages or banning users: a fuller list of sanctions is published in the full guidance)

You need to take reasonable and proportionate steps as necessary to prevent/remove banned content to comply with the law.

You will need to consider:

Policies you must publish

All traders who publish consumer reviews or consumer review information should publish policies which clearly prohibit fake reviews. These policies should also confirm the publisher’s approach to incentivised reviews and consumer review information.  

Completing a risk assessment

You must assess the risk of banned content being published in content you control.

Your risk assessment should:

• assess the risks that consumers may encounter banned reviews and false / misleading consumer review information on your media
• identify appropriate measures to address such risks effectively
• consider relevant evidence and information, including, but not limited to:
  • your own identification procedures *concerns flagged up to you by users and others
  • findings of investigations or internal evaluations that you carry out

Assessing the risk is not a one-off exercise: you should do so regularly, and especially if you are planning to make any changes to the way you operate that might increase the risk of banned information appearing.

Processes you must have in place

As well as publishing the required policies and assessing the risks, you must design processes that help you to:

• detect banned reviews and false or misleading consumer review information, and prevent these from being published in the first place  
• investigate suspected banned reviews and false or misleading consumer review information
• take actions in response to banned reviews and false or misleading consumer review information in order to remove this content and reduce the risk of it reappearing

You should regularly assess how effective your processes for preventing and removing reviews are. These processes should respond to any emerging risks or threats you observe.

Deciding what is reasonable for your circumstances 

You should have in place policies and procedures that are based on your individual circumstances.

What is reasonable for your business will depend on the circumstances of each case and on what is proportionate to the need to effectively prevent, and remove from publication, the banned material.

Factors to consider in deciding what is reasonable and proportionate include:  

• the incentives and opportunities people have for posting fake content in the particular area you operate in
• the source of the consumer reviews or consumer review information that you publish, such as whether users can publish directly on your site, or if they are first published on a site controlled by someone else
• the functionality you have on your site for sharing or promoting reviews
• the type of content you show to consumers 
• the potential impact of the activity on the traders being reviewed 
• any additional risks resulting from the impact or potential impact of banned reviews on aggregated consumer review information