Fake Reviews and the DMCC Act: What the CMA’s Actions Mean for UK Businesses
Recent undertakings from Google & Amazon provide clarity on what the regulator sees as good practice
On 6 June 2025, the UK’s Competition & Markets Authority issued a press release to share details of a set of mutually agreed commitments from Amazon to take action against fake reviews on their platform.
The Digital Markets, Competition and Consumers Act 2024 includes new requirements for online platforms to take ‘reasonable and proportionate steps’ to limit and reduce the presence of fake and misleading consumer reviews on their platforms.
This latest press release, when read alongside the CMA’s agreements with Google in January 2025 and ‘fake reviews guidance’ published in April 2025, provides clear insights into what are likely to be accepted as ‘reasonable and proportionate steps’ and provides a framework for other platforms to reach a compliance position.
Recap – what does the DMCC Act require in relation to fake reviews?
Under the Digital Markets, Competition and Consumers (DMCC) Act 2024, platforms that host or publish consumer reviews are required to take “reasonable and proportionate steps” to prevent, detect, and remove fake and misleading reviews.
This includes ensuring that reviews reflect genuine consumer experiences, identifying and removing reviews that have been incentivised without clear disclosure, and avoiding the publication of reviews in a way that could mislead users.
The Act places a duty on platforms not only to refrain from posting or facilitating fake reviews themselves, but also to actively manage the risks associated with third-party content, with failure to do so potentially resulting in enforcement action by the CMA.
The legislation itself does not prescribe exactly what constitutes ‘reasonable and proportionate steps’, and expectations may vary depending on the size, resources, and risk profile of the platform. To support companies in understanding what is expected of them, the Competition and Markets Authority (CMA) issued detailed guidance in April 2025, outlining practical measures and good practices that businesses can adopt to comply with the law.
Common commitments from Google and Amazon
It is positive to see the CMA proactively engaging with major platforms like Google and Amazon ahead of formal enforcement under the DMCC Act, securing clear undertakings that should help ensure these companies are in compliance with the new rules on fake reviews. This collaborative approach provides clarity for the wider market and sets a benchmark for what robust compliance can look like in practice.
Across both sets of commitments, there are some notable common themes:
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the introduction of enhanced detection systems to identify and remove fake or misleading reviews;
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the implementation of stronger sanctions for users and businesses that repeatedly engage in fake review practices, including suspensions and bans;
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rollout of improved user reporting mechanisms to make it easier for consumers to flag suspicious content.
Support with DMCCA compliance
The shared measures identified above offer useful indicators of what the CMA considers to be “reasonable and proportionate steps” under the fake reviews section of the DMCC framework.
It is advisable for other platforms to carefully review the CMA’s guidance alongside the undertakings secured with Google and Amazon to understand the standards expected under the DMCC Act, and assess whether their existing processes and controls to detect and remove fake or misleading reviews are adequate and aligned with these examples of best practice.
This includes evaluating the effectiveness of their review monitoring systems, the clarity and accessibility of their reporting tools, and the strength of their enforcement actions against offenders. By proactively reviewing and enhancing their approach, companies can better manage risks, protect consumer trust, and ensure compliance with their legal obligations under the new framework.
Members are also encouraged to get in touch with techUK if you have any questions or areas that need clarification and we will happily raise these to the relevant enforcement teams.
Essential Reading
CMA guidance on fake reviews: https://www.gov.uk/government/publications/fake-reviews-cma208
Jan 2025 press release (undertakings from Google): https://www.gov.uk/government/news/cma-secures-important-changes-from-google-to-tackle-fake-reviews
June 2025 press release (undertakings from Amazon): https://www.gov.uk/government/news/amazon-gives-undertakings-to-cma-to-curb-fake-reviews
Contact
For more information about techUK’s work on the DMCC Act, please contact [email protected]
Lewis Walmesley-Browne
Lewis' programmes cover a range of policy areas within Market Access (international trade regulation, sanctions and export controls, technical standards and product compliance, supply chains) and Consumer Tech (media and broadcast policy, consumer electronics, and connected home technology).
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