The DMCCA review rules, in plain English.

01What actually changed

Fake reviews used to live in a legal grey zone: misleading, sometimes actionable, rarely enforced. The DMCCA ended that. Fake reviews are now on the UK's list of automatically unfair commercial practices — the same list as pyramid schemes and false "closing down" sales. There is no wriggle room, no intent test, and no need for a regulator to prove consumers were actually harmed.

The Act received Royal Assent in May 2024. The CMA's new consumer enforcement powers — including the power to fine businesses directly, without going to court — went live in April 2025.

02What counts as a "fake review"

Broader than most owners expect. The banned practices cover:

• Writing or commissioning fake reviews — including asking staff, friends, or an agency to post as customers.
• Undisclosed incentives — "free dessert for a 5-star review" is a breach unless the incentive is disclosed on the review itself.
• Review suppression — hiding, deleting, or declining to publish genuine negative reviews while publishing positive ones.
• Cherry-picking who gets asked — systematically inviting only customers you know were happy ("review gating") can amount to presenting a misleading overall picture.
• Publishing reviews without checks — displaying consumer reviews without taking reasonable and proportionate steps to ensure they're genuine.

03Who is liable

The business whose products or services are being reviewed — not just the platform hosting the reviews. If a fake review sits on your profile, the duty to have prevented it sits with you, regardless of whether you knew about it. This applies to businesses of every size: the Act makes no exemption for independents or sole traders.

04The penalties

Up to the greater of £300,000 or 10% of annual global turnover, imposed directly by the CMA. For a large chain, 10% of turnover is the number that matters. For an independent café, the £300,000 floor is the number that matters — it can exceed a year's entire revenue.

Want to know your exposure? Use our fine calculator →

05What the CMA is already doing

Enforcement is not theoretical. In March 2026 the CMA opened formal investigations into five businesses — including Just Eat, AutoTrader, and Pasta Evangelists — over suppressing negative reviews, inflated star ratings, and undisclosed incentives. CMA announcement, 27 March 2026 →

If household names are being investigated, the mechanism that reaches smaller businesses is simple: a complaint. A competitor, a disgruntled ex-employee, or a mystery shopper is enough to put your review practices in front of the regulator.

06A practical compliance checklist

What "reasonable and proportionate steps" looks like for an independent business:

• Invite every customer, not just happy ones. Make the review ask part of the standard visit — receipt, QR code, follow-up message.
• Never incentivise without disclosure. If you reward reviews at all, the reward must be disclosed on the review. Safest: don't incentivise.
• Keep negative reviews up. Respond to them publicly instead. A profile with only 5-star reviews is itself a red flag to the CMA — and to customers.
• Verify reviewers are real customers. Keep evidence connecting reviews to genuine visits — booking records, receipts, or a verification system.
• Keep an audit trail. If the CMA asks "how do you know these reviews are genuine?", you need an answer in writing, not a shrug.
• Brief your staff. A well-meaning employee posting a 5-star review of their own workplace is now a legal liability, not a favour.

07Where Heard fits

Heard exists because the last two checklist items are hard to do manually. Every review on Heard is voice-verified — a real person, at a real location, at a real moment in time — and every profile carries a compliance-grade audit trail you can hand to a regulator. Negative reviews stay up, incentives aren't part of the model, and verification is the default rather than an afterthought.

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This guide is general information for UK businesses, not legal advice. For advice on your specific circumstances, consult a solicitor. Sources: Digital Markets, Competition and Consumers Act 2024; CMA guidance and enforcement announcements (gov.uk).