CMA secures undertakings from Amazon to combat fake reviews

The question

What do Amazon’s undertakings reveal about the CMA’s expectations for businesses in complying with consumer protection laws on fake reviews?

The key takeaway

The Competition and Markets Authority (CMA) has demonstrated its readiness to tackle fake consumer reviews by securing undertakings from Amazon to curb the prohibited practice on its marketplace. Following the enactment of the Digital Markets, Competition and Consumers Act (DMCCA), fake reviews are one of a number of unfair commercial practices in the CMA's crosshairs, with the regulator actively reviewing hosting platforms to ensure compliance. 

The background

As reported in our Spring 2025 edition of Snapshots, the consumer protection provisions under the DMCCA came into force on 6 April 2025. The DMCCA expressly prohibits a range of unfair commercial practices that were previously provided for under the Consumer Protection from Unfair Trading Regulations 2008, in addition to several new prohibitions relating to reviews which are either not based on genuine experiences or misleading consumer reviews (including concealed incentivised reviews). The DMCCA places a positive obligation on businesses to take “reasonable and proportionate” steps to prevent and remove these types of reviews.

The CMA has recently produced standalone guidance covering fake reviews in which it suggests the following steps for businesses to ensure compliance:

• the publication and implementation of a clear policy banning fake or misleading reviews, and setting out the business’s approach to incentivised reviews (either not allowing in any circumstances or allowing them but requiring them to be clearly and prominently disclosed)
• conducting regular risk assessments of consumers being exposed to fake or misleading reviews on the business’s platform, and
• taking a proactive approach – putting in place systems and processes to mitigate, identify and address the risks. For example, clear rules on who can submit reviews, requiring conditions such as verification of accounts or the fact that the consumer has purchased or used the product or service. Businesses should also try to deter fake reviews by taking strong action in response (ie appropriate sanctions).

The development

 In June 2021, the CMA launched a formal investigation into alleged consumer law breaches by Amazon, one of the world's largest online marketplaces, who was accused of failing to identify and take action against fake reviews and suspicious reviewing behaviour on its website. The investigation also focused on the practice of 'catalogue abuse' which is where sellers hijack the reviews of high performing products and add these reviews to unrelated products in a bid to boost their star ratings. 

In June 2025, as a result of this investigation, Amazon gave undertakings to the CMA that it would take steps to improve its processes in combating fake reviews, including in the following ways: 

• carrying out regular assessments of the risks to consumers in relation to the impact of fake reviews on consumer decision making, and putting in place appropriate measures to mitigate such risks
• putting in place improved measures to detect and respond to fake reviews, including through the implementation of thresholds which, when met, will result in a review being removed
• providing consumers with accessible mechanisms through which to report fake reviews and those responsible for them, and
• applying sanctions to sellers and reviewers responsible for fake reviews, including the ceasing of commercial relationships or placing limits on reviewing privileges.  

It should be noted that the CMA's investigation was launched under the Enterprise Act 2002, the predecessor of the DMCCA, such that Amazon's undertakings have been given pursuant to the previous consumer protection regime. Nevertheless, the undertakings demonstrate the CMA's intention to crack down on hosting platforms who, in its view, are not doing enough to curb the proliferation of fake and misleading reviews.

Why is this important?

The CMA’s action against Amazon underscores the growing regulatory pressure on businesses to tackle fake and misleading consumer reviews. Under the DMCCA, the CMA now has direct enforcement powers, allowing it to impose penalties without court approval. With the regulator actively reviewing platforms that host consumer reviews, businesses can no longer afford to take a passive approach. Robust systems to detect, prevent and respond to fake reviews are essential, not only to ensure legal compliance, but also to protect consumer trust and reputational value in increasingly competitive digital marketplaces.  

Any practical tips?

Businesses should take proactive steps to ensure compliance with consumer protection rules to avoid enforcement action. This includes implementing a clear, well-communicated policy on consumer reviews, supported by systems that detect and remove fake or misleading reviews. Businesses should also consider introducing verification measures for reviewers and enforcing appropriate sanctions against those responsible for abuse. Regular staff training and risk assessments will help embed good practices and demonstrate a robust approach to compliance.