title: "Could Your Shop Be Next? The CMA Is Coming for Fake Reviews" slug: cma-fake-reviews-crackdown-2026 date: 2026-03-29 author: ComplianceAlert excerpt: "The CMA named 5 businesses in new consumer enforcement cases this week. Autotrader, Just Eat, Dignity. Any UK business that has ever filtered reviews or offered an incentive for a positive one is now exposed. Fines up to 10% of global turnover — no court order needed." tags: ["CMA", "fake reviews", "consumer law", "DMCC Act", "retail compliance", "UK compliance"] sector: ["retail", "e-commerce", "hospitality", "professional services"] image: /images/blog/cma-fake-reviews.jpg

Could Your Shop Be Next? The CMA Is Coming for Fake Reviews

On March 27, 2026, the Competition and Markets Authority did something it's never done before.

It named five businesses in new consumer enforcement proceedings — not for price fixing, not for cartel behaviour, but for fake reviews.

The companies? Autotrader and Feefo (alleged suppression of negative reviews), Dignity (staff writing fake reviews), Just Eat (inflated ratings), and Pasta Evangelists (undisclosed discount-for-reviews scheme).

And under the Digital Markets, Competition and Consumers Act 2024 that came into force last year, the CMA doesn't need a court order to fine them.

It can fine businesses up to 10% of global annual turnover on its own authority. No judge. No tribunal. Just a finding of fact and a fine.

That changes everything — for every business with a review profile.

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What the CMA Actually Did

The five new cases opened on March 27 bring the total number of businesses under formal CMA investigation for fake reviews to 14.

Each case involves a different type of alleged conduct:

Autotrader / Feefo — Feefo is accused of allowing businesses using its platform to suppress negative reviews, showing only selected positive feedback to consumers. Autotrader is implicated as a platform user.

Dignity — The funeral services company is accused of having staff write positive reviews of their own business. Not customers. Staff.

Just Eat — Accused of using inflated ratings that don't accurately reflect verified customer feedback.

Pasta Evangelists — Allegedly offered discounts or vouchers in exchange for positive reviews, without disclosing that the review was incentivised.

These are not edge cases. These are practices that are widespread across British retail, hospitality, and professional services.

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The Real Question: Could This Be You?

Be honest with yourself. Has your business ever done any of the following?

• Offered a discount, voucher, or gift in exchange for leaving a review?
• Asked customers to leave a review only if they were happy (self-selecting for positives)?
• Had a staff member, friend, or supplier write a positive review?
• Used a platform or agency that filtered, curated, or "managed" your review profile?
• Removed or reported negative reviews you believed were unfair?

If the answer to any of these is yes, you have potential exposure under the current CMA enforcement framework.

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The Law: What Changed in April 2025

The fake reviews ban became active in April 2025 under the DMCC Act 2024. But there's a critical distinction many businesses missed: the fake reviews ban and CMA enforcement powers activated together.

Before the DMCC Act, the CMA had to take businesses to court to impose fines. It was a slow, expensive process — which meant only the largest, most egregious cases were pursued.

Now, the CMA can investigate, find a breach, and fine — all without a court hearing. The process is faster, cheaper for the CMA to run, and far more likely to be used against mid-market businesses.

The prohibition is clear:

• Creating, commissioning, or facilitating fake reviews is illegal
• Offering incentives for reviews without disclosure is illegal
• Suppressing or not publishing negative reviews is illegal
• Hosting reviews you know are fake is illegal

"Fake" is defined broadly. A review is fake if the reviewer was incentivised (without disclosure), if the reviewer has a conflict of interest, or if it was written by someone without genuine first-hand experience.

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What "No Court Order Needed" Actually Means

This is the part that most businesses haven't grasped.

The DMCC Act 2024 gives the CMA what regulators call a "direct enforcement" power. In practice:

1. CMA opens an investigation
2. CMA conducts evidence gathering (it has power to compel documents, interview witnesses)
3. CMA forms a provisional decision
4. Business has opportunity to respond
5. CMA issues final decision — including fine, if applicable
6. Business can appeal to the Competition Appeal Tribunal (but pays the fine first)

The timeline from investigation opening to fine can be under 12 months. The fine can be up to 10% of global annual turnover — not UK turnover, global.

For a business with £2m global revenue, that's potentially a £200,000 fine.

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Why Retail and Hospitality Are Most Exposed

Reviews are the lifeblood of these sectors. A single star difference on Google or Trustpilot can shift footfall meaningfully.

The pressure to maintain high ratings is real. And many of the practices under investigation are normalised — industry-standard, even. "Leave us a review and get 10% off your next visit" has been a common hospitality marketing tactic for years.

It's now a potentially unlawful incentivised review — unless it's disclosed to the reader that the reviewer received a benefit.

Similarly, agencies that offer "review management" services — filtering out negative reviews from being published — are now in legally dubious territory. If you're paying one, that's worth a conversation with a lawyer.

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What About Third-Party Platforms?

If you collect reviews through a third-party platform (Trustpilot, Google Business, Feefo, Trustist, Tripadvisor), you have obligations as well as the platform.

You are responsible for:

• Not incentivising reviews without disclosure
• Not instructing the platform to suppress negatives
• Not encouraging selective submission (asking happy customers to review, staying silent to unhappy ones)

The Feefo/Autotrader case is instructive. Feefo is the platform; Autotrader is the business using it. The CMA is pursuing both. You are not insulated by using a third party.

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The Drip Pricing Investigation Is Running Simultaneously

It's worth noting that fake reviews isn't the only CMA consumer enforcement wave underway.

The CMA opened its first cases under the DMCC Act's drip pricing provisions in January 2026. Drip pricing — adding unavoidable charges (booking fees, service charges, delivery fees) only at checkout — is now prohibited under the same framework.

If your business displays one price and adds mandatory extras at checkout, you are potentially subject to a separate investigation track.

The CMA has explicitly signalled that 2026 is an active consumer enforcement year. These are not isolated cases — they are the beginning of a systematic enforcement programme.

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What to Do Right Now

1. Audit your review practices

Pull together every review-related activity you've run in the past 12 months. Any campaign that offered an incentive for a review. Any instruction to a platform to manage your profile. Any internal guidance to staff. Document it.

2. Stop any non-disclosed incentive schemes immediately

If you're running a "leave a review, get a discount" promotion without disclosing that the review is incentivised in the review itself, stop. The law requires the disclosure to be visible to the reader of the review — not just to the reviewer.

3. Review your platform agreements

Check whether any review platform you use offers "review moderation", "profile management" or similar services. Request in writing what they do with negative reviews. Get clarity.

4. Don't instruct selective solicitation

Training your front-of-house team to ask satisfied customers for a review (and not ask unhappy ones) is self-selecting for positive feedback. While this is a grey area, the CMA's current approach suggests it falls within the scope of what they consider a misleading practice.

5. Update your marketing policies

Any social media offer, email marketing campaign, or loyalty scheme that involves reviews should be reviewed by someone with knowledge of the DMCC Act framework.

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Stay Ahead of the CMA

The five businesses named this week will not be the last. The CMA has allocated budget and resource for this programme through 2026-27.

The pattern of enforcement typically follows media attention. Once these cases are reported widely — and they will be — the next wave of businesses to come under scrutiny will be those in the same sector doing the same thing.

ComplianceAlert monitors CMA regulatory publications, enforcement notices, and sector guidance. When the CMA issues guidance relevant to your sector — whether it's on fake reviews, drip pricing, subscription contracts, or AI-driven pricing — you'll be alerted before it becomes an enforcement risk.

Start your 7-day free trial at ComplianceAlert.co.uk — no credit card, no contract.

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