Fake Reviews and Drip Pricing Are Illegal From Sunday — The CMA Has Already Named 5 UK Businesses
Fake Reviews and Drip Pricing Are Illegal From Sunday — The CMA Has Already Named 5 UK Businesses
From Sunday 6 April 2026, fake reviews and drip pricing become illegal under UK consumer law. The Competition and Markets Authority (CMA) has already opened five formal investigations — and its new powers under the Digital Markets, Competition and Consumers Act (DMCC Act) mean it can fine businesses up to 10% of global annual turnover without going to court.
If your business has ever asked staff to write a five-star Google review, offered a discount in exchange for a positive Trustpilot post, or added booking fees at the checkout that weren't visible on the product page — you need to read this before Sunday.
What Changes on Sunday 6 April?
The DMCC Act 2024 introduces two categories of prohibited commercial practices that become enforceable from April 6:
1. Fake Reviews — What's Now Illegal
The following practices are explicitly prohibited:
- Commissioning fake reviews — paying for reviews from people who haven't purchased your product or service
- Suppressing negative reviews — filtering, hiding, or removing genuine negative reviews from your public profile
- Incentivised reviews without disclosure — offering discounts, free products, or cashback in exchange for reviews without making the incentive transparent
- Writing reviews yourself or using staff — any internal person posting as a customer without disclosure
- Review manipulation via third parties — using review management platforms that game ratings through non-genuine submissions
The rules apply regardless of which platform the reviews appear on: Google, Trustpilot, Feefo, TripAdvisor, Amazon, Yelp, or your own website.
2. Drip Pricing — What's Now Illegal
Drip pricing means advertising a headline price and then revealing mandatory extra charges during the purchase journey. From April 6 this is unlawful. Specifically banned:
- Advertising a product at one price and only revealing a mandatory delivery charge at checkout
- Showing "from £X" pricing where the real price for most buyers is substantially higher
- Pre-ticking optional extras (insurance, enhanced packaging, warranty) to inflate the final price
- Adding a "service fee" or "booking fee" only visible at the final payment screen
- Any other mandatory charge not included in the prominently advertised headline price
Optional charges (such as gift wrapping or express delivery) may still be shown separately — but mandatory costs must be in the headline price.
The CMA Has Already Opened 5 Investigations
On 27 March 2026 — ten days before the law comes into force — the CMA announced formal enforcement proceedings against five businesses:
| Business | Alleged breach |
|---|---|
| Autotrader | Suppression of negative reviews |
| Feefo | Alleged platform-level manipulation enabling review suppression |
| Dignity Funerals | Staff writing fake reviews |
| Just Eat | Inflated aggregate ratings through non-genuine submissions |
| Pasta Evangelists | Discount-for-reviews scheme without disclosure |
These aren't small operations. Autotrader is a FTSE 250 company. Just Eat processes millions of orders per month. The CMA is sending a clear signal: size is not protection.
What makes these cases significant isn't the specific businesses — it's the timing. The CMA launched these investigations before the law fully comes into force. That means enforcement infrastructure is in place and ready to move immediately after April 6.
Why This Is Different From Previous Consumer Law
Under the old Consumer Protection from Unfair Trading Regulations 2008, the CMA had to take businesses to court to impose fines. That process took years and cost significant legal resource — which is why enforcement was rare and mostly targeted large businesses.
Under the DMCC Act, that changes entirely. The CMA can now:
- Investigate and fine directly — no court order required
- Issue fines of up to 10% of global annual turnover — not UK turnover, global
- Fine on a per-infringement basis — multiple reviews could mean multiple fines
- Impose compliance orders — requiring businesses to change their practices within a fixed timeframe
- Apply to courts for enhanced penalties if compliance orders are ignored
This is the most significant change to consumer enforcement powers in a generation. The CMA now has powers comparable to the ICO for data protection — and the ICO fined UK businesses £2.8m on average in 2025 alone.
Who Is Exposed?
The honest answer is: almost every UK business with a public review profile or an online checkout.
You are at risk if you have:
- A Google Business profile with more than a handful of reviews
- A Trustpilot, Feefo, or TripAdvisor profile
- An e-commerce checkout that adds any mandatory charge (delivery, handling, service fee) after the initial product page
- Staff who have ever been asked to leave a review "to help the business"
- Loyalty scheme incentives tied to leaving positive reviews
Sectors with the highest exposure:
- Hospitality — Google, TripAdvisor, and delivery app ratings are existential. Many operators have informal norms around staff reviews.
- Retail (online and physical) — delivery fees revealed at checkout are endemic in UK e-commerce.
- Professional services — law firms, dental practices, accountants with client review campaigns
- Funeral sector — Dignity's case signals the CMA is looking at emotionally sensitive sectors
- Automotive — Autotrader's case signals this applies to lead-generation platforms, not just direct sellers
What You Need to Do Before Sunday
This is not a long-term strategic project. You have four days.
For Reviews
Step 1: Audit your review acquisition process How do customers currently end up leaving reviews? Is there any element of incentive, coaching, or filtering? Document the process.
Step 2: Check your review management platform If you use a third-party platform (Feefo, Trustpilot Pro, Reviews.io, etc.), check whether it offers any "negative review filtering" or "invitation management" that suppresses low scores. If it does, either disable that feature or get written confirmation from the provider that it complies with the DMCC Act.
Step 3: Update your review invitation wording Any email or text asking for a review must not suggest, imply, or reward a positive score. Compliant wording: "We'd love to hear your honest feedback" — not "If you enjoyed your visit, we'd really appreciate a 5-star review."
Step 4: Disclosure for any incentivised scheme If you run any promotion where customers receive a benefit for leaving a review, the promotional nature must be clearly disclosed on the review itself. If your platform doesn't support disclosure, stop the scheme.
For Pricing
Step 5: Audit your checkout journey Walk through your own checkout process as a customer. Note every charge that appears after the initial product page. Any mandatory charge that isn't included in the headline price needs to be moved to the displayed price — or removed.
Step 6: Update your advertising and product listing prices If your product listings show "£X + delivery" and delivery is mandatory (not genuinely optional), the delivery cost must be included in the displayed price or shown at the point the customer first sees the product — not revealed later.
Step 7: Check pre-ticked extras Any optional add-on at checkout (insurance, gift wrapping, priority delivery) must be unticked by default. Customers must actively choose to add it.
The ComplianceAlert Angle
ComplianceAlert monitors CMA enforcement and sends alerts when new enforcement actions are announced — including when businesses in your sector come under investigation.
Knowing that Dignity is under investigation for fake reviews isn't directly actionable for your funeral home. But knowing that the CMA is actively looking at the sector, two weeks before a law change, is a very strong signal about where their post-April-6 enforcement attention will be.
That's the value of monitoring: not just the regulation, but the enforcement pattern.
Not sure if your business is exposed? Take our free 3-minute Compliance Score quiz — 20 questions, instant results, no sign-up required: 👉 compliancealert.co.uk/compliance-score
Frequently Asked Questions
Does this apply to all review platforms? Yes. The DMCC Act applies to any review about your business on any platform — including Google, TripAdvisor, Facebook, Amazon, Trustpilot, Feefo, and your own website.
What if a third-party platform creates fake reviews about my business without my knowledge? You are not liable for reviews you did not commission or facilitate. However, if you use a platform's tools to manage or filter reviews, you may be liable for how those tools function.
Is it illegal to ask customers to leave a review? No. Asking customers for honest, unbiased reviews is completely legal. What's illegal is incentivising positive reviews (without disclosure), suppressing negative ones, or creating fake reviews.
Does drip pricing apply to B2B sales? The DMCC Act primarily targets business-to-consumer (B2C) transactions. Business-to-business pricing is generally not covered. However, if your business sells both B2C and B2B through the same channels, the B2C elements must comply.
What about Amazon Marketplace sellers? Yes — if you sell through Amazon or any marketplace to UK consumers, the DMCC Act applies to your review practices. Amazon itself has its own review compliance system, but the CMA can separately investigate seller behaviour.
Summary — What the DMCC Act Means for Your Business
From Sunday April 6:
- Fake reviews of any kind are illegal — this includes suppression, incentivisation without disclosure, and internally created reviews
- Drip pricing is illegal — all mandatory charges must be included in the headline price
- The CMA can fine up to 10% of global annual turnover without going to court
- 5 investigations are already open — enforcement will move immediately after April 6
The businesses that get fined first won't be the ones who deliberately cheated. They'll be the ones who had informal review practices that nobody documented, or checkout flows that evolved piecemeal and never got audited.
Four days to clean this up. Don't be on the list.
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