The Digital Markets, Competition and Consumers Act 2024 brings major updates to UK consumer protection laws. One key change is the restriction on fake or misleading online reviews, aimed at promoting trust and fair competition in online markets.
The Act received Royal Assent in May 2024, with its main consumer-facing provisions, including those on reviews, taking effect from 6 April 2025. This newsletter outlines what the new rules mean for businesses.
Why online reviews are under scrutiny
Online reviews significantly influence commercial decisions. A large proportion of prospective customers, both individuals and businesses, consult reviews before choosing a supplier, product, or service. However, when reviews are fake or manipulated, the market becomes distorted.
Government research suggests that more than 10 percent of reviews in some product categories may be fake. This damages trust and puts companies that rely on genuine feedback at a disadvantage.
Businesses must not create or pay for fake reviews
Under the new Act, it is illegal to post a fake review or arrange for someone else to do so. Reviews must reflect genuine customer experiences. Incentives for positive reviews, such as discounts or gifts, are also prohibited unless clearly disclosed.
For example, a hotel offering a free night in exchange for a review must declare that arrangement. These rules apply to both staff and external agencies, and the business remains responsible regardless of who is involved.
Manipulating how reviews are presented is also banned
The Act also addresses how reviews are presented. Highlighting only positive feedback or removing criticism may now breach the law.
Reviews must be balanced and transparent, with star ratings reflecting genuine experiences. For example, if a platform displays only five-star reviews while hiding lower ratings, it may be in breach of the rules.
Verifying that published reviews are legitimate
Businesses that display customer reviews must take reasonable steps to ensure they are genuine. This includes moderating content, detecting fake submissions, and removing suspicious material.
While complete accuracy may not be possible, systems should be in place to reduce manipulation. Examples include fraud detection tools or purchase verification. These expectations apply across all sectors.
Pricing transparency and hidden fees
The Act also addresses pricing practices. So-called drip pricing, where unavoidable fees are added late in the transaction, is now restricted. Businesses must disclose the full price, including compulsory charges such as booking fees, taxes, or service costs, at the beginning of the process.
Optional extras can still be offered but must be clearly distinguished. The CMA will take action where pricing information is incomplete or ambiguous.
Tighter rules on subscription contracts
Another key part of the reforms focuses on subscriptions and auto-renewals. Businesses must clearly set out the terms of any subscription before a contract is formed. Consumers must also be reminded before the subscription renews, particularly in the case of annual or long-term agreements.
Most importantly, the cancellation process must be straightforward. The law requires that exiting a contract should be no more difficult than signing up.
The new rules offer layered protection
These measures protect consumers and support businesses that operate transparently. Firms that rely on genuine feedback are often undercut by those using dishonest tactics.
The CMA can now impose penalties of up to 10 percent of global turnover without going through the courts, making enforcement faster and more likely.
How 3CS can help
The Digital Markets, Competition and Consumers Act 2024 introduces new legal duties around online reviews, pricing, and subscriptions. 3CS Solicitors advise clients on how these rules apply in practice, helping to manage risk and ensure compliance. To discuss how we can support your business, get in touch today.
