TL;DR

UK product review compliance changed fundamentally in April 2025 when the Digital Markets, Competition and Consumers Act 2024 (DMCCA) came into force. Fake reviews are now a banned practice, concealed incentivised reviews are illegal, and fines can reach 10% of global turnover. Incentivised reviews remain legal if properly disclosed. This glossary defines every key term FMCG brand teams need to understand, maps each one to the law, and explains what it means in practice for brands generating reviews on UK retailer websites.

Why Product Review Compliance Matters Now

The CMA estimates that £23 billion of UK consumer spending is influenced by online reviews each year. That figure alone explains why the UK government decided to get serious about regulation. But for FMCG brand teams, the stakes are more specific than a national statistic.

Reviews drive retailer search ranking, conversion on product detail pages, and even whether a product survives a range review. Products with fewer than 20 to 30 reviews struggle to cross what shoppers consider a credibility threshold. Yet the average grocery review rate sits at just 0.1% to 0.3%, creating intense pressure to generate volume quickly. That pressure is exactly where compliance risk lives.

Since April 2025, the DMCCA has given the Competition and Markets Authority direct enforcement powers over product review practices. The CMA wasted little time using them. By March 2026, it had launched investigations into five businesses, including Pasta Evangelists, a food brand accused of offering discounts for five-star reviews without disclosure. The message is clear: product review compliance in the UK is no longer optional, and food and drink brands are not exempt.

For brands looking to build review volume the right way, understanding compliant review generation is now a prerequisite, not an afterthought.

The Regulators: Who Enforces What

Before getting into definitions, it helps to know which bodies are watching and what powers each one holds.

CMA (Competition and Markets Authority)

The CMA is the primary enforcer of the DMCCA’s review provisions. It can investigate businesses directly, impose fines of up to 10% of global annual turnover, and hold individual directors personally liable. It does not need to prove that a consumer was actually misled; if the practice falls within the Act’s banned list, that alone is enough to trigger enforcement.

ASA and the CAP Code

The Advertising Standards Authority operates the UK’s self-regulatory system for advertising. Its Committee of Advertising Practice (CAP) Code includes rules 3.44 to 3.46, which specifically address fake consumer reviews in marketing communications. The ASA handles complaints and can require content to be removed, but it cannot impose financial penalties the way the CMA can. Where a review crosses the line into advertising (more on this below), the ASA takes the lead.

Trading Standards

Local Trading Standards offices can also enforce consumer protection law. In practice, they are less likely to investigate review compliance at scale, but they remain a statutory enforcement body.

Retailers

Tesco, Sainsbury’s, Asda, and other major grocers each operate their own review moderation policies. These sit on top of the legal framework. A review that is technically lawful might still be rejected by a retailer’s moderation team if it fails their internal guidelines. Retailers are also “publishers” of consumer review information under the DMCCA, which creates their own compliance obligations and makes them less tolerant of brands that cut corners.

Glossary of Key Terms

The following terms are grouped by theme rather than alphabetically, because understanding how they relate to each other matters more than finding them in a list.

The Law and the Regulators

DMCCA 2024 (Digital Markets, Competition and Consumers Act)

The primary UK legislation governing product review compliance. Its consumer protection provisions came into force on 6 April 2025. The Act introduced a blacklist of 32 banned commercial practices, several of which relate directly to reviews. It replaced the Consumer Protection from Unfair Trading Regulations 2008 and gave the CMA powers to fine businesses without going through the courts.

Why it matters for FMCG brands: any brand that commissions, incentivises, publishes, or syndicates product reviews in the UK is subject to this law.

Banned Practice (Schedule 20)

One of 32 commercial practices the DMCCA declares unfair in all circumstances. The fact that they are on the blacklist means the CMA does not need to prove consumer harm; the practice itself is the offence. Fake reviews, concealed incentivised reviews, and certain forms of review manipulation all appear on this list.

Compliance tip: there is no “it didn’t actually mislead anyone” defence. If the practice is listed, it is banned, full stop.

CAP Code (Rules 3.44 to 3.46)

The advertising rules that mirror the DMCCA’s review provisions. Rule 3.44 prohibits fake consumer reviews in marketing communications. Rule 3.45 requires clear disclosure when reviewers have been incentivised, including free products, payments, or discount vouchers. Rule 3.46 addresses the suppression or cherry-picking of reviews.

These rules matter most when a review crosses into advertising territory (see “Editorial Control” below).

Types of Reviews

Consumer Review

The DMCCA defines this as “a review of a product, a trader or any other matter relevant to a transactional decision.” This is deliberately broad. A review on a Tesco PDP, a comment on a brand’s own website, a social media post about a product, even a video review on YouTube can all qualify. For a deeper look at what makes a review genuinely authentic in the FMCG context, the distinction between organic, incentivised, and fabricated content is critical.

Fake Review

A consumer review that “purports to be, but is not, based on a person’s genuine experience.” This includes reviews written by someone who never used the product, reviews written by company employees posing as customers, reviews generated by AI to simulate customer feedback, and reviews purchased from review farms.

Publishing or commissioning fake reviews is a banned practice under Schedule 20. No grey area.

Incentivised Review

A review where the reviewer received something of value, whether a free product, a discount, a voucher, or payment, in connection with leaving the review. Incentivised reviews are legal under the DMCCA, provided two conditions are met: the incentive is clearly disclosed within the review, and the incentive is not conditional on the review being positive.

This distinction is the single most important concept in product review compliance for UK brands. The line between lawful and unlawful is not the incentive itself, it is the disclosure. For brands weighing the pros and cons, the differences between a review service and influencer gifting come down largely to how each model handles this disclosure requirement.

Concealed Incentivised Review

An incentivised review where the incentive has not been disclosed. This is a banned practice. The CMA’s guidance uses a clear example: “the consumer was given the product for free in return for providing a review, but the incentivisation has not been made clear.” The Pasta Evangelists investigation centres on exactly this scenario, where customers were allegedly offered discounts on future orders in exchange for five-star reviews on delivery apps without disclosure.

Verified Purchase Review

A review tied to a confirmed purchase of the product from the specific retailer where the review appears. Verified purchase reviews carry more weight with both consumers and retailer moderation teams because they prove the reviewer actually bought and (presumably) used the product. This model is structurally safer from a compliance perspective because the purchase itself is the foundation of authenticity. For a full breakdown, see our guide to verified product reviews.

Review Manipulation Concepts

Review Gating

The practice of screening customers before they leave a review, typically by asking about their experience first and only directing satisfied customers to the public review page. Dissatisfied customers are redirected to a private feedback channel. Review gating is a form of review suppression and falls foul of the DMCCA’s prohibition on misleading publication of consumer reviews.

Misleading Publication

Presenting reviews in a way that creates a false impression of customer sentiment. This includes cherry-picking positive reviews, suppressing or deleting negative ones, publishing only a selected subset of reviews, or presenting incentivised reviews alongside organic ones without differentiation.

Star Rating Inflation

When a product’s aggregate star rating is artificially higher than genuine customer opinion would produce. This can happen through review gating, selective publication, undisclosed incentivised reviews, or a combination. The CMA’s investigation into Just Eat relates to exactly this concern. Importantly, the DMCCA covers aggregate scores as part of “consumer review information,” so a distorted star rating is itself a compliance issue, not just the individual reviews behind it.

Consumer Review Information

This is one of the most underappreciated terms in the whole framework. The DMCCA defines it to include not just individual reviews but aggregated data: overall ratings, review counts, and rankings. If incentivised reviews inflate a product’s star rating on a retailer PDP, the star rating itself becomes misleading consumer review information, making both the brand and the retailer potentially liable.

The Review Supply Chain

Publisher

Under the DMCCA, any business that publishes consumer review information has specific obligations. In the context of UK grocery, the retailer (Tesco, Sainsbury’s, Asda) is typically the publisher because reviews appear on their websites. But a brand that publishes reviews on its own site, or a platform like Bazaarvoice that syndicates reviews across sites, can also be a publisher.

Publishers must take “reasonable and proportionate steps” to prevent fake or misleading reviews from appearing.

Review Syndication

The practice of collecting reviews on one platform and distributing them to appear on other websites. For example, a brand might collect reviews on its own site via Bazaarvoice, then syndicate those reviews to appear on Tesco or Sainsbury’s PDPs. Syndication creates a specific compliance risk: the disclosure that accompanied the original review might not carry over to the destination site. If a syndicated review was incentivised but appears on a retailer PDP without that disclosure visible, the review is non-compliant at the point of publication.

A loveMONEY investigation found that on Tesco, Sainsbury’s, and Asda websites, thousands of reviews for certain products were sourced from brands’ own websites and from people who had received products for free. Some major branded products had unusually high review counts, many sourced from platforms like Influenster. This is the compliance flashpoint where review syndication meets the DMCCA’s disclosure requirements.

Editorial Control

This is the dividing line between a review and an advertisement. The ASA’s position is clear: if the marketer has any editorial control over material published by a third party, the content is advertising, not a review. If a brand can approve, edit, or reject a review before it goes live, that review is an ad and must comply with the full CAP Code, not just the review rules.

For FMCG brands running sampling campaigns, this means hands-off is the only compliant posture. You can ask a shopper to leave an honest review. You cannot script it, edit it, approve it before publication, or require a minimum star rating.

Risk Assessment

The DMCCA places a positive obligation on publishers to conduct risk assessments of their review processes. This is not a suggestion. Publishers must proactively identify where fake or misleading reviews might enter their systems and take steps to prevent it. For brands, the practical implication is that retailers will increasingly demand evidence that your review generation process is compliant before they allow reviews from your campaigns onto their PDPs.

Compliance Requirements

Disclosure and Labelling Requirements

CAP Code Rule 3.45 specifies that where a reviewer has been incentivised, the review must clearly state this. The disclosure must be prominent and specific, covering payment, free products, or discount vouchers. A vague “some reviewers may have received complimentary products” note buried in a page footer does not meet the standard. The disclosure needs to appear within or immediately adjacent to the review itself.

Reasonable and Proportionate Steps

The standard the CMA expects businesses to meet when preventing fake or misleading reviews. It is deliberately flexible, recognising that a small brand’s capabilities differ from a multinational’s. But flexibility is not a free pass. The CMA expects documented processes, active moderation, and responsive action when problems are identified.

Review Policy

The CMA’s guidance strongly encourages businesses to publish a clear review policy explaining how they collect, moderate, and display reviews. Tesco’s published policy is a model: it states that incentivised reviews are permitted only when the incentive is clearly disclosed, incentives must not be contingent on a positive rating, and non-compliant reviews will be removed. Brands should have their own internal review policy and ensure it aligns with every retailer’s policy where their products appear.

Emerging Compliance Areas

AI-Generated Review Summaries

Retailers and platforms are increasingly using AI to generate summaries of product reviews (the “customers love the flavour but find the packaging fiddly” box at the top of a review section). These summaries are subject to the DMCCA if the AI is not properly trained. If the model is built to skew positive and downplay negative reviews, the resulting summary is misleading consumer review information. This is a new area with no enforcement precedent yet, but the legal position is clear.

What FMCG Brands Can and Cannot Do

Allowed

Incentivised reviews with clear, prominent disclosure within each review. Review generation campaigns where real shoppers buy a product at a retailer, use it, and post an honest review. Asking customers to leave reviews via email or post-purchase prompts, provided there is no filtering or gating. Including both positive and negative reviews in your published review content.

Banned

Concealed incentivised reviews (any incentive not disclosed). Paying for positive-only reviews or making any reward conditional on a specific rating. Suppressing or deleting negative reviews to inflate sentiment. Publishing reviews written by employees, agency staff, or anyone without genuine product experience. Commissioning fake reviews from review farms or generating them with AI. Review gating in any form.

Grey Areas

Syndicated reviews that were properly disclosed on the originating site but appear without disclosure on the destination retailer site. AI-generated review summaries that may inadvertently weight incentivised reviews differently. Review campaigns where a free product is provided but the brand claims no review was “required” while making it implicitly clear one was expected.

The safest structural model for product review compliance in the UK is the verified purchase approach: a real shopper buys the product at the retailer, uses it, posts an honest review with disclosure, and the retailer’s own systems verify the purchase. This approach is compliant at every layer, the law, the CAP Code, and the retailer’s own moderation policy.

Brands starting from scratch should focus on getting their first 30 reviews the right way, because reviews generated compliantly are durable. Reviews generated through shortcuts can disappear overnight in an enforcement action, taking the conversion lift with them.

How Retailers Handle Compliance

UK grocers are not passive in this space. They have their own reputations and legal exposure to protect.

Tesco

Tesco publishes a formal Ratings and Reviews Policy stating that incentivised reviews are allowed only when incentives are “clearly and prominently disclosed within the rating or review,” incentives are not contingent on a positive rating, and non-compliant reviews will be removed. Brands whose review campaigns do not meet Tesco’s requirements will see reviews rejected at moderation, wasting time and budget.

Sainsbury’s

Sainsbury’s partners with Bazaarvoice to collect, moderate, and display reviews. Bazaarvoice uses automated tools and human moderators to verify that each review comes from real customers. This creates an additional moderation layer that syndicated or incentivised reviews must pass through.

What This Means for Brands

If you are commissioning reviews for products sold on UK grocer websites, you need to satisfy both the legal framework (DMCCA plus CAP Code) and the retailer’s specific policy. These are not always identical. A retailer can and will reject reviews that technically comply with the law but fail their own internal standards. Checking each retailer’s review policy before launching a campaign is essential. Our retailer review launch checklist covers this step by step.

Penalties and Enforcement Cases

The Penalty Structure

The DMCCA’s penalties are designed to hurt, even for large businesses:

• Fines of up to 10% of global annual turnover or £300,000, whichever is higher
• Ongoing fines of up to 5% of daily turnover or £15,000 per day for continued breaches
• Personal liability for directors or managers who knew about or allowed breaches

These are not theoretical maximums. The CMA fined AA/BSM £4.2 million under the DMCCA’s drip pricing provisions, a different offence but the same enforcement powers. The willingness to issue seven-figure penalties is established.

The Enforcement Timeline

The CMA gave businesses a three-month grace period from April 2025. During that window, it focused on education rather than penalties. When the grace period ended in July 2025, the CMA swept over 100 businesses and found that more than half might need to improve their compliance. It issued advisory letters to 54 firms, 90% of which made changes in response.

From April 2025 to April 2026, the CMA launched consumer law investigations into 14 businesses and settled with two, issuing 157 advisory and warning letters in total.

Key Cases for FMCG Brand Teams

The five investigations opened in March 2026 are the most relevant:

Pasta Evangelists is under investigation for allegedly offering customers discounts on future orders in exchange for five-star reviews on delivery apps, without disclosing the incentive. This is a food brand. On a delivery platform. Offering a discount. For a specific star rating. Without disclosure. It hits every prohibition in the book.

Just Eat is being investigated over how reviews and ratings are presented on its platform, raising questions about star rating inflation and review information accuracy.

Feefo and Autotrader face scrutiny over their review publishing practices, confirming that platforms and aggregators, not just brands, are in scope.

As one legal commentator noted, these cases confirm that the rules “don’t just apply to large platforms.” Brands can find themselves investigated even if they don’t host reviews on their own site.

A Compliance Checklist for Review Campaigns

Use this as a quick reference before launching any product review campaign in the UK.

1. Confirm genuine purchase. Every reviewer should have bought the product from the retailer where the review will appear. This creates the strongest compliance foundation.

2. Disclose every incentive clearly. If the reviewer received anything of value (free product, discount, voucher, entry into a prize draw), it must be stated within the review itself, not in a footnote or separate page.

3. Never condition incentives on a positive review. The reviewer must be free to leave a one-star review and still receive the incentive.

4. Do not exercise editorial control. Do not approve, edit, or reject reviews before publication. If you do, the content becomes advertising under the CAP Code.

5. Publish all reviews, positive and negative. Do not gate, filter, or selectively publish reviews.

6. Check syndication disclosure. If reviews are syndicated from one site to another, verify that the incentive disclosure travels with the review.

7. Audit your aggregate scores. If incentivised reviews are inflating your star rating on a retailer PDP, the rating itself may be misleading consumer review information.

8. Align with each retailer’s review policy. Check Tesco, Sainsbury’s, Asda, and every other retailer’s specific requirements before submitting reviews.

9. Document your process. The “reasonable and proportionate steps” standard requires evidence. Keep records of your review policy, your disclosure practices, and your moderation approach.

10. Review AI-generated summaries. If your retailer or platform uses AI to summarise reviews, check whether the summary accurately reflects the full range of customer feedback, including negatives.

For a more detailed walkthrough of campaign planning, our product review campaign compliance guide covers each step in depth.

Product review compliance in the UK is not a burden. It is a competitive advantage. Brands that build their review presence on a compliant foundation own durable, trustworthy UGC that survives regulatory scrutiny, passes retailer moderation, and earns genuine consumer trust. Brands that take shortcuts risk losing every review in a single enforcement action. If you are ready to build review volume that lasts, explore how Brand Allies works with UK FMCG brand teams.

Frequently Asked Questions

Are incentivised product reviews legal in the UK?

Yes. The DMCCA does not ban incentivised reviews. It bans concealed incentivised reviews, meaning reviews where the incentive was not disclosed. As long as the incentive is clearly stated within the review and is not conditional on a positive rating, the review is compliant.

Who counts as a “publisher” under the DMCCA?

Any business that makes consumer review information available to consumers. In practice, this includes retailers (Tesco, Sainsbury’s), review platforms (Bazaarvoice, Feefo), and brands that display reviews on their own websites. Each publisher has a positive obligation to take reasonable steps to prevent fake or misleading reviews.

Can we give shoppers a free product in exchange for a review?

Yes, provided the review clearly discloses that the product was received for free. The reviewer must also be free to share their genuine opinion, including negative feedback. You cannot require a minimum star rating or positive sentiment.

What happens if syndicated reviews lose their disclosure labels?

If an incentivised review appears on a retailer site without the original disclosure, it becomes a concealed incentivised review at the point of publication. Both the brand that commissioned the review and the retailer that published it could be liable. Always verify that disclosure labels carry through the syndication process.

What are the maximum fines for product review non-compliance?

The CMA can fine businesses up to 10% of global annual turnover or £300,000, whichever is higher. For ongoing breaches, daily fines of up to 5% of daily turnover or £15,000 per day apply. Directors who knew about or permitted breaches can face personal liability.

Does the DMCCA apply to star ratings and aggregate scores?

Yes. The Act covers “consumer review information,” which explicitly includes aggregate ratings, review counts, and rankings. A star rating inflated by undisclosed incentivised reviews or selective publication is itself a compliance issue, separate from the individual reviews behind it.

Are AI-generated review summaries in scope?

Yes. If an AI system generates a summary of product reviews and that summary is skewed (for example, trained to emphasise positives and downplay negatives), it constitutes misleading consumer review information under the DMCCA. This is an emerging area with no enforcement precedent yet, but the legal framework clearly covers it.

How quickly is the CMA enforcing these rules?

Rapidly. After a three-month grace period ending July 2025, the CMA conducted a sweep of over 100 businesses and found more than half needed to improve. By March 2026, it had opened formal investigations into five businesses, including a food brand. Between April 2025 and April 2026, it issued 157 advisory and warning letters across the sector.