Coalition for Trusted Reviews: One Year On from the CMA’s Fake Reviews Guidance
Introduction
One year on from the CMA’s Unfair Commercial Practices (UCP) and Fake Reviews Guidance, the UK’s approach to increasing consumer trust continues to evolve. As Government and regulators respond to rapid technological change, particularly the rise of AI, the challenge is no longer just identifying fake reviews, but addressing how and where they are generated, and how best to intervene across an increasingly complex digital ecosystem, often crossing many jurisdictions.
One year into UCP: progress and open questions
The past year has seen clear first steps from the CMA as it seeks to enforce the Fake Reviews Guidance published in April 2025. Towards the end of last year, the regulator contacted companies after reviewing 100 businesses, finding that over half could be failing to comply with the new guidance. The CMA also recently launched investigations into the compliance of several companies, demonstrating that expectations are shifting from soft guidance to more proactive oversight.
As the regulator embodies Government’s broader “growth steer” by supporting the principles of the “4Ps” (pace, predictability, proportionality and process), engagement with industry has been notably constructive. Ongoing dialogue has supported businesses to better understand both compliance expectations and enforcement direction, with Coalition for Trusted Reviews members and wider industry welcoming the regulator’s recognition that there is no “one-size fits all approach” and that platforms’ different functionalities must be accounted for.
However, questions still remain about what enforcement efforts can have the greatest impact. From the Coalition’s perspective, this must move further upstream. While platforms’ own interventions on their own services remain integral, there is significant value in tackling fake reviews at their point of origin, before they enter the wider ecosystem. This means focusing on the entire supply chain that enables fake reviews, including the networks of bad actors that generate and distribute them.
Such an approach would require more targeted enforcement against organised sources and sellers of fake reviews, and greater coordination between regulators internationally, reflecting the inherently cross-border nature of bad actors. At the heart of this would be continued dialogue with industry to identify vulnerabilities and useful points of intervention.
In short, effective enforcement will depend not only on ensuring that platforms are doing enough to tackle fake reviews, but also on recognising their place within a broader chain and addressing the root cause of the problem.
Direction of Government’s policy
The UK Government’s broader policy direction is still crystallising through its recently published Fraud Strategy.
A centrepiece of this strategy is the proposed Online Crime Centre, a public-private hub designed to enable real-time intelligence sharing and coordinated disruption of bad actors across sectors. This collaborative approach aligns with the Coalition’s ongoing efforts to proactively identify and tackle targeted fraud, such as organised fake review sellers. By leveraging industry insights into emerging risks and international best practices, the Coalition is well-positioned to help the Government strengthen its response.
Alongside this, Government intends to introduce new metrics to assess fraud prevalence and industry response, including for online platforms. This signals a shift toward more outcome-based scrutiny of how effectively different parts of the ecosystem are tackling fraud.
While the Government currently relies on existing frameworks like the Online Safety Act and the Digital Markets, Competition and Consumer Act, it has established a clear escalation pathway. New metrics will be used to assess the industry's effectiveness in tackling fraud, with a warning that the Government remains prepared to legislate further if these outcomes are not met.
Growing political and public attention
There is also increasing parliamentary focus on the issue. The Chair of the Business and Trade Committee, Liam Byrne, recently highlighted the scale of consumer harm in digital markets, pointing to fake reviews alongside scams and unsafe products as part of a wider “consumer rip-off” facing UK households. In a digital landscape increasingly cluttered by scams and fraudulent activity, consumers rely on online reviews to better navigate risks and identify value.
This growing political attention reflects a broader recognition: trusted reviews are not a niche concern, but a foundational feature of well-functioning digital markets.
A critical moment for reviews
For the Coalition for Trusted Reviews and wider industry, this is a pivotal moment.
The Coalition continues to advance industry best practices designed to protect consumer trust and remains in active dialogue with the CMA and other stakeholders. However, the landscape is shifting rapidly.
AI is transforming how reviews can be generated, scaled and manipulated, raising new risks for sure, but we see greater opportunities for detection and verification. At the same time, we are seeing some jurisdictions trying to give businesses more control over the reviews that are written about them, including the right to demand their removal. This risks undermining the efforts of platforms and inadvertently suppressing genuine reviews.
Against this backdrop, it is more important than ever that the UK maintains a balanced, collaborative approach, working closely with industry to develop proportionate, effective solutions that most effectively respond to the issue at hand.
Looking ahead
The first year of the CMA’s guidance has laid important foundations. The next phase will be defined by how effectively regulators, Government and industry can work together to identify bad actors and focus upon enforcement upstream in the ecosystem, act internationally, and respond to technological change.
For trusted reviews, and the consumers who rely on them, getting this balance right has never been more important.