Picture a text that goes out after every visit: "How did we do? Tap a star." Tap four or five, and the next screen opens your Google review page. Tap one to three, and it opens a private feedback form. That one screen is a step Google's policy does not allow.
So what does UK fake reviews law, the DMCC Act, let you do? You can ask customers for reviews. Guidance from the Competition and Markets Authority (CMA) says asking in general, without steering what people say, is "not prohibited under the banned practice". Fake reviews, hidden incentives and showing reviews in a misleading way are banned.
Checked against the Act, the CMA's guidance, Google's policy and the guidance of the Information Commission (the ICO) on 3 October 2026. WebAsk is a web agency, not a law firm. This summarises published law and guidance; it is not legal advice.
TL;DR
Ask every customer the same way, offer nothing for a Google review, and show what comes back as it is. The DMCC Act bans fake reviews, hidden incentives and misleading display, and Google does not allow asking only the happy customers.
What the DMCC Act bans
Since 6 April 2025, the Digital Markets, Competition and Consumers Act 2024 has listed four review practices as "in all circumstances considered unfair" (Schedule 20, paragraph 13). Such practices "are prohibited" (section 225). In short:
- Submitting, or commissioning someone to submit or write, a fake review, or one that "conceals the fact it has been incentivised".
- Publishing reviews, or review information such as overall ratings, "in a misleading way".
- Publishing them without "reasonable and proportionate steps" against fake reviews, hidden incentives and false or misleading review information.
- "Offering services to traders" to do, or help do, the first two.
A fake review "purports to be, but is not, based on a person's genuine experience". Commissioning "includes incentivising by any means". The Act does not mention review gating, staff targets or prize draws.
What the CMA can do, and the five investigations
The CMA said on 27 March 2026 that its new consumer powers let it decide "whether consumer laws have been broken, without having to go through the courts". It can investigate, then issue a provisional and a final infringement notice (sections 180 to 182). Section 182 sets the penalty:
"The amount of a monetary penalty imposed under subsection (4)(b) must be a fixed amount not exceeding £300,000 or, if higher, 10% of the total value of the turnover (if any) of the respondent."
Turnover includes "turnover both in and outside the United Kingdom" (section 204). So: up to £300,000 or 10% of global turnover, whichever is higher. The business has a "right to appeal". These review practices are excluded from the Act's criminal offence for Schedule 20 (section 237). We did not assess other offences.
On 26 March 2026, the CMA opened investigations into five businesses "that it suspects may have infringed consumer law" over online reviews. One question is whether customers were offered "discounts on future orders in exchange for leaving 5-star reviews on delivery apps, without this being disclosed". The CMA says it "has not reached any conclusions about whether consumer law has been broken". The five case pages, listed by the CMA, were updated on 28 September 2026. Each reads "Investigation ongoing (next case update Winter 2026 to 2027)". We found no fine for reviews under the Act in the CMA's published cases on 3 October 2026.
Asking for reviews: what is allowed, at a glance
Each row gives the Act and the CMA's guidance, Google's policy as read on 3 October 2026, and our verdict. "Unsettled" means no source we read decides it.
| What you want to do | The Act and the CMA's guidance | Google's policy | Our verdict |
|---|---|---|---|
| Ask every customer, the same way | Asking "without predetermining the contents or sentiment" "is not prohibited under the banned practice" (CMA208 3.6) | Allowed "without offering incentives to do so or attempting to influence the rating or the contents of the review" | Yes. Whether it is marketing is unsettled |
| Ask only customers you expect to be happy | Not named in the Act; cherry-picking "might be done" this way (CMA208 4.5) | Merchants may not "selectively solicit positive reviews" | No. Google does not allow it; no CMA decision found |
| Ask for a private score first, then send the public link only to high scorers | As the row above | As the row above | No. Switch the step off |
| Pause requests after a bad review | Traders "should not" interfere by "arbitrarily stopping and starting review invitations" (CMA208 4.4) | Not named | No |
| Offer a discount, voucher or freebie | Allowed if disclosed and genuine (CMA208 3.7), but "likely to be misleading" where the platform bans it (3.4) | Not allowed "in exchange for posting any review" | Not for a Google review |
| Offer entry into a prize draw | Entry "is unlikely to amount to commissioning in the context of the banned practice" (CMA208, footnote 8) | Not named; its incentive examples begin "such as" | Unsettled on Google. Leave it off |
| Reply to reviews | A refund or gift card to change a review "so that it is no longer reflective of their genuine experience" is a commissioning example (CMA208, example 4) | No incentive for "revision or removal of a negative review" | Yes, with nothing offered |
| Ask on the premises | Not addressed | Merchants "should not require or pressure" reviews there | A displayed QR code, yes. Pressure, no |
| Give staff a review target, or script the words | Asking "without predetermining the contents or sentiment" "is not prohibited under the banned practice" (CMA208 3.6); staff targets not named | Not allowed: "Merchants requesting that staff solicit a certain number of reviews", or requesting "that specific content be included" | No |
| Show reviews on your own site | Publishing includes "making available, by any means" (para 13(5)(h)); the duty is "non-delegable" (CMA208 8.32) | Not addressed | Yes, with a published policy and checks |
| Filter a widget to four stars and above | Fits the Act's own example of a "misleading way" (para 13(5)(i)) | Not addressed | No |
| Let an agency run your requests | Offering services to do, or help do, fake reviews, hidden incentives or misleading display is itself banned (para 13(4)); CMA208 3.3 names "marketing companies" | Not addressed | Yes, if it follows the same rules |
Are you allowed to ask for Google reviews?
Yes, on conditions. The CMA's fake reviews guidance (CMA208, 4 April 2025) says, at paragraph 3.6:
"There are many instances in which traders may want to encourage the submission of reviews … Doing so without predetermining the contents or sentiment expressed in the review, for example by merely emailing customers generally to ask if they wish to provide a review, is not prohibited under the banned practice."
Google's policy lets merchants ask for reviews of "a genuine experience". The conditions are no incentives and no "attempting to influence the rating or the contents of the review". Its help page suggests your review link "on your receipts" and "in thank you emails". So keep the ask open: no suggested rating or words.
In the shop, salon or clinic
Google's help page also suggests you "Print and display the QR code in your store". But its policy says merchants "should not require or pressure users to leave ratings or write reviews while on the premises". That line includes "Merchants requesting that staff solicit a certain number of reviews". A code on the counter fits Google's tips. A staff target does not.
Is review gating illegal in the UK?
Review gating means asking only the customers you expect to be happy, for example after a private score. The Act does not name it. The CMA's guidance comes close, at paragraph 4.5:
"Cherry picking positive reviews for publication over negative ones might be done either through suppressing negative reviews that have been submitted or by encouraging just those who are satisfied to leave reviews."
A trader "may infringe the law" if they "selectively promote positive or negative reviews" (paragraph 4.3). We found no CMA decision on gating by 3 October 2026. Google's policy is plainer. It does not allow merchants to "selectively solicit positive reviews from customers". For a Google review, do not gate.
Pausing requests after a bad review
The CMA's guidance says traders "should not" get in the way of negative reviews. One example it gives is "arbitrarily stopping and starting review invitations" (paragraph 4.4). Keep requests running the same way, whatever the last review said.
Incentivised reviews: discounts, freebies and prize draws
The Act does not ban incentives. It bans hiding them. The CMA's guidance says, at paragraph 3.7:
"Traders may want to incentivise customers to leave a review for example by paying them, offering them future discounts or free products. Traders are free to do this but to comply with the law they must: (a) tell consumers that the review has been incentivised, and (b) the review must still reflect the reviewer's genuine experience."
Where a platform allows them, the review "must be clearly identifiable as incentivised". "Usually, it will be necessary for the reviewer at least to label the review prominently as incentivised, namely, as an advert" (paragraph 3.5).
Google does not allow them. Its policy rules out incentives "in exchange for posting any review". And where a platform does not allow incentivised reviews, the CMA says "submitting an incentivised review is likely to be misleading" (paragraph 3.4). A label does not make it allowed on Google. Offer nothing for a Google review.
On prize draws, the CMA's footnote 8 deals with "the chance to earn a reward which does not guarantee a direct benefit for the reviewer", such as entry into a prize draw. Offering that, it says, "is unlikely to amount to commissioning in the context of the banned practice". Google's policy does not name prize draws. Leave a draw off any Google request.
What Google does about fake and incentivised reviews
Google's policy says rating manipulation "includes incentivised or biased reviews, which are not allowed and will be removed from Maps". If a business owner breaks its fake engagement policy, Google "might place restrictions" on the profile. Its examples include no new reviews "for set period of time" and existing reviews "unpublished for set period of time". Another is "a warning to let consumers know that fake reviews were removed". Businesses can appeal.
Google has also given undertakings to the CMA. The CMA's notice of 24 January 2025 said UK businesses "found to be boosting their star ratings via fake reviews" will have "prominent 'warning' alerts". They will also "have their review function deactivated". Repeat offenders "will have all their reviews deleted for 6 months or more". Google gave the undertakings "without admission of liability or wrongdoing". Neither the undertakings nor Google's policy is the Act.
Is a review request a marketing message?
As far as we can find, the ICO has not said whether a review request is direct marketing. None of its guidance pages we read on 3 October 2026 mentions review requests. The ICO enforces the UK's electronic marketing rules, PECR.
Its Identify direct marketing page (latest update 20 August 2025) says:
"If your service message has elements that are direct marketing, even if that is not the main purpose of your message, then it will count as direct marketing."
If you are unsure, it says you should "think about why you want to communicate with people", for example "are you trying to influence their behaviour?" It also says to "look at whether the content is promotional", for example whether it would "promote you or your interests".
A text counts as "electronic mail" (PECR regulation 2). If a request is marketing, regulation 22 applies to individuals. "You must not send marketing emails or texts to individuals without specific consent", says the ICO's guidance on electronic mail marketing. There is a "limited exception for your own previous customers". That guidance "is under review and may be subject to change".
Our own design, not the ICO's ruling: a request that asks for a review and nothing else, with no offer in it.
Replying to reviews
Google checks replies against its content policies. Its tips say "Never share the reviewer's private info", and "there's no need to offer deals or promotions". Among the CMA's examples of commissioning is offering a customer "a refund and/or a gift card if they change their review to remove the negative commentary (so that it is no longer reflective of their genuine experience)". Google's policy rules out incentives for "revision or removal of a negative review". If a review breaks Google's policy, or you believe it breaks the law, our guide to getting a Google review taken down covers the routes.
Showing reviews on your own website
A review widget on your site counts as publishing, which "includes disseminating, or otherwise making available, by any means" (paragraph 13(5)(h)). The CMA calls a business that shows a platform's ratings on its own site a "second-party publisher". It says the duty to act against banned reviews is "non-delegable" (paragraph 8.32). If you want to rely on the platform's own checks, the CMA says you "should review" its "policies and arrangements for tackling banned content" to satisfy yourself, "on reasonable grounds", that they "meet the duty". If you cannot "find, evaluate and have reasonable confidence in" its procedures, you may need to take "more significant steps" yourself. The CMA's short guide adds: "You should have a published policy that clearly prohibits fake reviews."
Do not filter. The Act's examples of a "misleading way" include "failing to publish, or removing from publication, negative consumer reviews whilst publishing positive ones". A widget set to four stars and above does that.
Testimonials and a site's other legal duties are in our UK website legal checklist. For clinics, our clinic website checklist covers the extra rules on photos, testimonials and reviews.
If an agency or a tool runs your requests
The CMA's guidance for businesses and agencies (updated 28 August 2025) tells businesses using a marketing or SEO agency to "make sure they also follow these rules". So ask any provider three things: who sends the requests, what the message says, and whether any step filters who gets the link.
Offering traders services to do, or help do, fake reviews, hidden incentives or misleading display is itself banned (paragraph 13(4)). The CMA's fake reviews guidance (CMA208) names "marketing companies, individuals acting on behalf of traders". If they submit or commission banned reviews, they "will be in breach of the banned practice" (paragraph 3.3).
A checklist for any review set-up
- Every customer gets the same request, with no private score first.
- Requests are not stopped and started around bad reviews.
- Nothing is offered for a Google review.
- The request asks for a review and nothing else: no suggested rating, words or offer.
- Nobody is required or pressured to review on the premises, and staff have no review targets.
- A person checks each reply, and nothing is offered for a change or a removal.
- Any widget on your site shows reviews unfiltered, with a published policy against fake reviews.
- If someone else runs it, you know who sends the requests, what they say and whether any step filters who gets the link, and the rules still apply to you.
Where to start
- Check your set-up against the checklist above. Our local SEO checklist covers the other local search steps.
- Ask the same of any agency. Nothing in our SEO retainer buys or incentivises reviews.
- Talk to us. Get in touch with the searches you want to be found for.