UK Fake Reviews Hidden Fees Ban – CMA Rules and Compliance Guide

The United Kingdom has introduced sweeping new consumer protection measures that fundamentally change how businesses operating online must treat their customers. Effective from 6 April 2025, the Digital Markets, Competition and Consumers Act 2024 (DMCCA) grants the Competition and Markets Authority (CMA) direct enforcement powers against two particularly damaging practices: fake reviews and hidden fees that appear late in the purchasing process.

These measures address what the government estimates costs UK consumers £2.2bn annually in unnecessary charges. The legislation targets sectors ranging from food delivery platforms to event ticketing websites, where manipulative pricing tactics have become increasingly common. For businesses selling goods or services online, compliance is no longer optional.

The enforcement landscape has shifted dramatically. The CMA can now investigate companies, impose sanctions, and levy substantial fines without needing to go through the courts first. This represents a significant departure from previous consumer protection arrangements and signals a new era of regulatory accountability for the digital marketplace.

Are Fake Reviews Illegal in the UK?

Yes. Under the new legislation, fake reviews are now explicitly prohibited across all UK-facing online platforms. The ban covers posting, commissioning, or failing to moderate fake, incentivised, or manipulated reviews. Platforms must ensure that reviews are genuine and come from verified purchasers or users with authentic experiences.

The rules apply to both the platforms hosting reviews and businesses that operate on them. Review websites similar to Trustpilot face particular obligations under these rules, as do online marketplaces where third-party sellers rely on review systems to build trust with potential customers.

• Businesses face fines up to 10% of their global annual turnover for violations
• By November 2025, the CMA had already investigated eight companies and warned more than 100 others
• The ban covers both posting fake reviews and commissioning them from others
• Platforms are now legally responsible for moderating reviews on their sites
• International online sellers serving UK customers must also comply
• The legislation targets sectors including food delivery, ticketing, travel, and marketplaces

What Does the UK Ban on Fake Reviews and £2.2bn Sneaky Fees Cover?

The legislation addresses a broad spectrum of deceptive commercial practices that have become endemic across UK online shopping. The government identified these practices as causing significant financial harm to consumers while creating unfair competitive advantages for businesses willing to mislead their customers.

Scope of the Fake Reviews Prohibition

The fake reviews ban goes beyond simply prohibiting fabricated testimonials. It encompasses several related practices that can distort the online review ecosystem. Businesses cannot pay individuals to write positive reviews, offer incentives in exchange for favourable feedback, or suppress negative reviews through intimidation or reward schemes.

Platforms themselves bear responsibility for the integrity of reviews appearing on their sites. They must implement systems to detect and remove fake reviews, verify that reviewers have actually purchased or used the products they are reviewing, and take action against businesses that systematically manipulate their review profiles.

For online marketplaces where third-party sellers operate, the obligations extend to monitoring seller behaviour and ensuring compliance across the platform. This means that large e-commerce operators serving UK consumers need robust verification systems and moderation capabilities.

Additional Banned Practices

Beyond fake reviews and drip pricing, the legislation targets several other manipulative commercial tactics. These include aggressive sales techniques designed to pressure consumers, false information about products or services, unfair contract terms buried in lengthy terms and conditions, misleading countdown timers that create false urgency, artificial scarcity claims, and default opt-ins for additional paid extras.

The CMA published guidance before the ban came into effect, summarising 32 specific practices that would be treated as violations. Further guidance is expected following a consultation process during summer 2025, with finalised guidance anticipated in autumn 2025.

What is Drip Pricing and Why is it Now Banned in the UK?

Drip pricing refers to a practice where businesses advertise a low base price but gradually reveal additional mandatory charges only as the customer progresses through the checkout process. These mandatory fees, which can include administration charges, booking fees, delivery costs, or service levies, were previously only disclosed when customers had already invested time in selecting their purchase and were psychologically committed to completing the transaction.

Under the new rules, all mandatory fees that customers cannot avoid must be included in the headline price displayed from the outset. This means the first price a consumer sees should reflect the total amount they will need to pay before any extras are added. The intent is to allow consumers to make informed comparisons between competing offers without encountering unpleasant surprises at checkout.

What Remains Permissible

The legislation does not ban all additional charges. Optional extras that customers can choose to add or decline remain allowed, provided they are clearly presented as optional. Examples include seat selection on transport bookings, priority delivery upgrades, or optional insurance packages. The key distinction is between charges that are mandatory and charges that represent genuine optional enhancements to a purchase.

Businesses selling on Amazon UK or operating food delivery services similar to Hello Fresh UK must ensure their pricing structures comply with these requirements. Any unavoidable fees, whether labelled as service charges, platform fees, or booking costs, must now appear in the initial price shown to consumers.

Industries Most Affected

The sectors identified as most commonly employing drip pricing tactics include event ticketing platforms, where booking fees routinely appeared only at checkout, food delivery services that added platform or delivery charges after menu selection, travel booking websites showing base fares before revealing taxes and charges, and various online retail platforms that applied additional mandatory fees at the point of purchase confirmation.

What Role Does the CMA Play in Enforcing Fake Reviews Bans?

The Competition and Markets Authority serves as the primary enforcement body for these new consumer protection measures. The DMA received direct enforcement powers under the legislation, removing the need to pursue court proceedings before investigating potential violations or imposing sanctions. This represents a significant expansion of the regulator’s capabilities.

The CMA’s approach combines strict enforcement of clear violations with support for businesses attempting to comply with the new requirements. The authority has emphasised its commitment to creating a level playing field where businesses that have invested in fair practices are not disadvantaged by competitors employing deceptive tactics.

Enforcement Powers and Procedures

Under the new powers, the CMA can conduct investigations, issue warnings, require businesses to cease specific practices, and impose financial penalties without obtaining court orders. The maximum fine available is 10% of a company’s global annual turnover, a level of penalty that makes compliance a material business priority rather than a theoretical concern.

The regulator has indicated it will prioritise cases involving egregious violations, systematic fake review manipulation, significant drip pricing operations, and practices that particularly target vulnerable consumers. However, the authority has also stressed its willingness to work with businesses, especially small and medium-sized enterprises, to achieve compliance before resorting to formal enforcement action.

Business Compliance Requirements

Platforms and online sellers face several specific obligations under the new regime. They must audit their websites and applications to ensure pricing transparency, train staff on the requirements, implement systems to detect and remove fake reviews, monitor third-party sellers for compliance, and maintain records demonstrating their efforts to meet the new standards.

The CMA has signalled that it will conduct audits examining headline prices, checkout flows, and promotional tactics across UK-facing online retail. Businesses should review their customer journey from initial price display through to purchase confirmation to identify any practices that might fall within the scope of the prohibited activities.

Timeline: Key Dates in the UK Fake Reviews and Hidden Fees Ban

Understanding when different aspects of the legislation came into effect helps businesses and consumers appreciate the development of this regulatory framework.

1. Pre-2025: The CMA conducts investigations into online commercial practices under existing consumer protection legislation, building evidence for stronger measures.
2. 2024: The Digital Markets, Competition and Consumers Act receives Royal Assent, establishing the framework for new consumer protections.
3. Pre-launch (early 2025): The CMA issues guidance summarising 32 banned practices, providing businesses with information needed to prepare for compliance.
4. 6 April 2025: Key provisions covering fake reviews and drip pricing come into force, marking the official start of the new enforcement regime.
5. Summer 2025: Expected consultation on additional guidance, allowing stakeholders to provide input on implementation details.
6. Autumn 2025: Final guidance anticipated following the consultation process, providing clearer direction on compliance expectations.
7. November 2025: CMA reports that it has investigated eight companies and warned more than 100 others for violations, demonstrating active enforcement.
8. 2025-2026: Ongoing enforcement activity expected, with the CMA continuing to prioritise high-impact breaches.

The timeline reflects a phased approach to implementation, with initial guidance followed by a period of enforcement experience and consultation before finalised guidance emerges. Businesses should monitor CMA communications for updates as this process develops.

What Is Established and What Remains Unclear

While the core elements of the legislation are well-established, several aspects of the framework continue to evolve as enforcement experience accumulates and guidance develops.

Context: Why These Measures Were Introduced

The decision to introduce specific legislation addressing fake reviews and drip pricing reflects growing recognition that existing consumer protection frameworks were inadequate for addressing deceptive practices in digital markets. The £2.2bn annual cost to consumers represents a substantial economic impact that accumulated over years of increasingly sophisticated manipulative techniques.

Consumer advocacy groups had documented widespread frustration with discovering unexpected charges only at checkout, while investigations repeatedly found that significant proportions of online reviews on major platforms were suspected of being fabricated or incentivised. Traditional enforcement mechanisms proved too slow and cumbersome to address practices that evolved rapidly and exploited gaps between different regulatory jurisdictions.

The UK approach draws partly on regulatory developments in other jurisdictions while addressing specifically UK consumer protection priorities. By granting direct enforcement powers to the CMA, Parliament aimed to create a more agile regulatory response capable of keeping pace with changes in commercial practices.

These new rules will end the shock of extra fees being added at the end of the online shopping process and give consumers greater control over their purchasing decisions while supporting economic stability.

— Minister Justin Madders, Department for Business and Trade

We will tackle harmful practices proportionately and work constructively with businesses seeking to comply, while taking firm action against those who break the rules.

— Sarah Cardell, Chief Executive, Competition and Markets Authority

Summary

The UK ban on fake reviews and hidden fees represents the most significant expansion of consumer protection for online shopping in recent years. The Digital Markets, Competition and Consumers Act 2024 created enforceable obligations that apply to all businesses serving UK consumers, with the CMA equipped to impose penalties of up to 10% of global turnover without court proceedings. For businesses operating in sectors like food delivery, ticketing, and online marketplaces, understanding and implementing compliance is now an urgent priority. The enforcement activity already underway demonstrates that the regulator is serious about addressing these practices, making proactive compliance the sensible approach for any business with UK customers.

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