Reviews sell products, and the law has noticed. Regulators in the United States, the United Kingdom and the European Union have each set rules in recent years about fake reviews, paid reviews and how a shop shows what customers say. A small store that does the honest thing most of the time can still slip: a staff member posts a five-star review, a review app hides the one-star ones, or reviews for a blue shirt are shown on the red one.
This guide sets out what three official sources say, in plain words, and ends with a checklist for your own review policy. I read the FTC's questions and answers, the CMA's guidance and the text of the EU directive on 11 November 2026. This is general information, not legal or tax advice. Check the current rules or ask a qualified adviser before you decide.
United States: the FTC rule
The Federal Trade Commission's questions and answers say its Consumer Reviews and Testimonials Rule took effect on 21 October 2024. They list what it prohibits:
- Writing, creating or selling fake or false reviews and testimonials, including ones that misrepresent the reviewer's real experience.
- Buying positive or negative reviews, meaning offering incentives that require a particular sentiment, stated or implied.
- Insider reviews, from people with a material connection to the business such as employees or relatives, that do not clearly disclose it. Generalised requests to customers are exempt.
- Pretending that a website you control provides independent reviews.
- Stopping reviews with intimidation, unfounded legal threats or knowingly false accusations.
- Buying fake social media indicators, such as bot followers.
Two points matter for a shop. First, a retailer that hosts customer reviews is generally not liable for them if it did not write or buy them, and has no duty to investigate or screen them. It can be liable if it wrote or bought reviews it knew, or should have known, were false. And reviews you feature in your advertising become testimonials, so the hosting exemption no longer applies to them. Second, incentives are not banned outright. You may offer one as long as nothing requires or implies a positive review, though the FTC notes that undisclosed incentives may still break the FTC Act. The page says courts can impose civil penalties for knowing violations but gives no amount, and the FTC adds that its staff answers are not definitive and give no safe harbour.
United Kingdom: the CMA guidance
The Competition and Markets Authority published its fake reviews guidance (CMA208) on 4 April 2025. It explains a banned practice under the Digital Markets, Competition and Consumers Act 2024. The guidance lists these as banned:
- Submitting fake reviews, positive or negative, that claim an experience that did not happen.
- Commissioning reviews, by paying or rewarding someone, including with discounts, free products or event invitations, or hiding the incentive. Reviews written for a reward must say so clearly, for example with a prominent label. You may offer an incentive, but the review must still reflect a genuine experience.
- Arranging or helping others to post fake or concealed reviews.
- Publishing reviews in a misleading way, such as suppressing genuine ones or merging reviews of different products.
For anyone who publishes reviews, retailers included, the guidance expects reasonable and proportionate steps to prevent and remove banned reviews. It lists a published policy, risk assessment, detection and verification, timely investigation, removing banned reviews, correcting ratings and review counts, sanctions such as banning accounts, and regular checks that the measures work. It says small traders are not exempt. On showing reviews fairly, it says publishers should not suppress genuine negative reviews, cherry-pick favourable ones, hide that a review was incentivised, merge reviews of materially different products, leave outdated reviews visible where a product has changed materially, or treat genuine negative reviews as complaints and withhold them. The document I read states no start date and no fine amount, so look at the CMA's pages for those.
European Union: telling shoppers how you check
Article 3 of Directive (EU) 2019/2161 changes the Unfair Commercial Practices Directive in two ways that matter here. It adds a new paragraph 6 to Article 7: if you give shoppers access to product reviews, then information about whether and how you check that the reviews come from people who actually used or bought the product counts as material information. And it adds two practices to the list of those always treated as unfair. Point 23b bans saying that reviews come from verified users or buyers without taking reasonable and proportionate steps to check. Point 23c bans submitting or commissioning false reviews or endorsements, and misrepresenting consumer reviews or social endorsements, to promote products. The Article 3 text does not show penalties. Those are in another article, which I did not read, so ask an adviser in each EU country you sell to about penalties and local rules.
What the three have in common
- Fake reviews are out, whether you write them, buy them or ask someone else to.
- Paid or rewarded reviews need care and, in the UK and the US, disclosure of the incentive.
- Do not hide or delete honest negative reviews.
- Do not claim reviews are verified unless you check.
- What you show is judged as a whole, not review by review.
The CMA also says small traders are not exempt, and that the effort expected should match the risk. A small shop does not need a compliance department, but it does need a written policy and someone who follows it.
A review policy checklist for your store
- Write a one-page policy: who may post, how reviews are checked, what you remove and why. Publish a short version on your site.
- Ban staff, relatives and agencies from posting reviews of your products without clear disclosure, and tell them.
- If you send review requests, send them to all buyers, not only those you expect to be happy.
- If you offer a reward, do not make it depend on a good rating, and label rewarded reviews clearly.
- Do not delete a negative review because it is negative. Remove only what breaks your published rules, such as abuse or spam, and keep a record.
- Check how variants are grouped. If reviews for different products are combined, ratings can mislead.
- Remove or flag old reviews that no longer describe the current product.
- If you say reviews are from verified buyers, make sure your system checks that.
- If you quote reviews in advertising, treat them as testimonials, and keep proof they are genuine.
- Review the policy twice a year, and after any change of review app.
Questions for your review app vendor
- How does it check that a review comes from a real buyer?
- Can reviews be hidden or filtered by rating, and can we switch that off?
- How are incentivised reviews labelled?
- Does it merge reviews across products or variants, and can we control that?
- What logs can we export if a regulator asks?
Honest reviews also help conversion. See our conversion optimisation page for how we work with store owners, and send a short brief on the contact page if you want help planning review collection. Our guide to privacy and cookies is useful if your review tool uses cookies or sends emails.
Sources
- Consumer Reviews and Testimonials Rule: questions and answers (Federal Trade Commission): effective date, banned practices, retailer liability, incentives, who is covered; staff answers are not definitive; page date not shown (checked 11 November 2026)
- Fake reviews guidance, CMA208 (Competition and Markets Authority, GOV.UK): published 4 April 2025; banned practices, publisher duties, showing reviews fairly (checked 11 November 2026)
- Directive (EU) 2019/2161, Article 3 (legislation.gov.uk copy): new Article 7(6) on telling shoppers how reviews are checked; Annex I points 23b and 23c on false reviews; penalties are in a different article, not read (checked 11 November 2026)