CMA signals end of grace period: Fake reviews enforcement steps up

On 25 July 2025, the Competition and Markets Authority (the CMA) confirmed a significant shift in its approach to fake or misleading online consumer reviews, signalling the end of the three-month grace period for businesses to comply with tough new obligations under the Digital Markets, Competition and Consumers Act 2024 (the DMCCA). 

The DMCCA requires consumer-facing businesses to take active steps to tackle fake or misleading online reviews and online review content. The CMA published guidance in April, setting out its views on how businesses should comply (here). Our own practical guide to compliance with this and other elements of the DMCCA is available here.

Having looked at the websites of more than 100 businesses, the CMA has now announced it is now writing to 54 companies whose websites show potential non-compliance with that guidance.

What does the CMA's announcement mean?

Tackling fake reviews is a key component of the CMA’s broader strategy to address digital consumer harms, such as drip pricing and subscription traps. Last Friday’s announcement indicates a sustained focus on ensuring fair practices in the digital economy.

The implications of this move are particularly significant for businesses active in e-commerce, hospitality, and any industry where reviews are a significant factor in consumer decision-making. 

So what are the key takeaways?

1. The process of the review: The CMA assessed whether companies had published policies on their websites prohibiting fake reviews and outlined their approach to incentivised reviews (reviews in exchange for a form of compensation). The CMA's pre-emptive website review suggests a continued commitment to proactive market monitoring and data-driven identification of non-compliance, rather than solely relying on consumer complaints. 
2. Warning letters: the CMA has said that it expects any company that receives a letter from the CMA to respond outlining what changes, if any, they have made or plan to make in response. 
3. Focus on publishers: the CMA’s focus remains firmly on any business that hosts or publishes consumer reviews. The DMCCA sets out a positive obligation for businesses to take “reasonable and proportionate steps” to prevent, detect, and remove fake or misleading reviews, and to ensure transparency around incentivised reviews.
4. Significant financial penalties for non-compliance: While these initial letters likely serve as a warning, they may foreshadow more robust enforcement by the CMA. Under the DMCCA, the CMA now possesses direct enforcement powers, enabling it to impose monetary penalties of up to 10% of a business’s global annual turnover for breaches of consumer law, as well as directions requiring the business to change its practices.  

Recent statutory undertakings given by Amazon and Google in relation to the steps that they will take to tackle fake/misleading reviews reinforce that this will continue to be an important area of focus for the CMA.

If you would like to discuss any aspect of the DMCCA, please contact a member of the team or your usual Freshfields contact. You can also subscribe to our client toolkit for further updates and insights.