Fake reviews law UK: what the DMCC Act means for dental practices

The fake reviews law in the UK is in the Digital Markets, Competition and Consumers Act 2024. Since 6 April 2025, Schedule 20 of the Act has listed fake reviews, reviews that hide an incentive, and publishing reviews in a misleading way as banned practices: commercial practices that are unfair in all circumstances. The Competition and Markets Authority can now enforce this directly and fine a business up to 10% of its global turnover.

For a dental practice, this covers far more than buying five-star reviews. Asking staff to review the practice, offering a discount for a review, and asking only happy patients can all fall inside it. This guide explains what the law says, how the CMA interprets it, and the changes most practices need to make.

What exactly is banned?

Paragraph 13 of Schedule 20 to the DMCC Act, in force from 6 April 2025, bans:

1. Submitting, or commissioning someone to submit or write, a fake consumer review. A fake review is one that claims to be, but is not, based on a person's genuine experience.
2. Submitting or commissioning a review that conceals it was incentivised. A review is incentivised if the person was commissioned to write it, and "commissioning" includes incentivising by any means.
3. Publishing reviews, or information derived from them, in a misleading way. The Act gives examples: removing or not publishing negative reviews while publishing positive ones, giving positive reviews more prominence, and leaving out how a review came to be written.
4. Publishing reviews without reasonable and proportionate steps to prevent and remove fake reviews, concealed incentivised reviews and false or misleading review information.
5. Offering services to traders to write, submit or publish reviews in any of these ways.

"Writing" includes creating by any means, which covers reviews generated with AI. "Consumer review information" includes star ratings, review counts and summaries.

How the CMA reads the law

The CMA published its fake reviews guidance (CMA208) in April 2025. Several points apply directly to dental practices:

• Staff reviews count as commissioned. The guidance says commissioning is not limited to money and gives the example of a trader asking a member of staff to write a review of its product.
• Incentives are any benefit. Money, discounts or vouchers, free products and invitations to events are all listed. Offering a refund or gift card to a patient to change a negative review is given as an example of a banned practice.
• Cherry-picking is misleading. The CMA says a trader may infringe the law if it suppresses genuine negative reviews or selectively promotes positive ones, and that cherry-picking can be done "by encouraging just those who are satisfied to leave reviews".
• Interfering with negative reviews is a problem. Traders should not threaten legal action, stop and start review invitations arbitrarily, or make dispute resolution conditional on a patient not leaving a negative review.
• Asking for reviews is fine. The guidance says that encouraging reviews without predetermining their content or sentiment, for example by emailing customers generally to ask whether they wish to leave one, is not prohibited.

Is review gating illegal?

Very likely, yes, under UK law. Review gating means checking whether a patient is happy first and only sending the satisfied ones to Google. The DMCC Act lists publishing positive reviews while not publishing negative ones as misleading, and the CMA's guidance names "encouraging just those who are satisfied to leave reviews" as a form of cherry-picking. Google's own policy separately prohibits businesses from selectively soliciting positive reviews.

The safe approach is to send the same review request to every patient after their visit, with no filter.

What is an incentivised review?

An incentivised review is one written in return for something: a discount on the next hygiene visit, a free whitening top-up, a voucher, entry into a draw. Under UK law an incentivised review is not banned outright, but it must be clearly disclosed as incentivised and must still reflect the reviewer's genuine experience, according to the CMA guidance.

In practice that does not help a dental practice on Google, because Google does not allow incentives at all. Its Maps content policy says merchants may not offer incentives, such as payment, discounts or free goods and services, in exchange for posting a review or for revising or removing a negative one. The CMA guidance notes that a prize draw which does not guarantee a benefit is unlikely to count as commissioning under the Act, but Google's policy still applies on Google.

What Google does about fake reviews

In January 2025 the CMA secured undertakings from Google. Where a UK business is found to have boosted its rating with fake reviews, Google will:

• show a prominent warning on the business profile saying suspicious activity has been detected
• switch off the business's ability to receive new reviews
• for repeat offenders, delete all reviews for six months or more

Google also agreed to make it easier for people to report reviews they suspect are incentivised. Google's policy goes further than fake reviews. It treats reviews based on a conflict of interest, including current or former employment, as rating manipulation, and says merchants should not ask staff to collect a set number of reviews or reviews that mention a particular staff member.

Can you get in trouble for writing fake reviews?

Yes. A practice that writes, commissions or publishes fake or concealed incentivised reviews is committing a banned practice. The CMA can investigate and, if it finds an infringement, require changes and impose fines of up to 10% of global turnover. On 27 March 2026 it opened investigations into five businesses over issues including negative reviews not being published, staff being asked to write positive reviews, and discounts offered for five-star reviews without disclosure. Agencies and freelancers who offer to write or post reviews for a practice are also covered by the ban.

The commercial risk often arrives first. A warning on your Google profile, or losing the ability to receive reviews, would cost a practice far more than any fake review gained.

Are fake testimonials illegal?

Yes. The CMA guidance says a consumer review does not have to be written by a consumer and can appear offline, for example in marketing letters, so a testimonial about your practice or treatment is very likely to be treated as a consumer review, and a fake one is banned in the same way. The advertising code is also clear. The CAP Code requires marketers to make clear where consumer reviews have been incentivised (rule 3.45), not to publish reviews in a misleading way (3.46), and to hold documentary evidence that a testimonial is genuine along with contact details for the person who gave it (3.47).

Dental professionals have a further duty. The GDC's Standards for the Dental Team require any advertising or promotional material you produce to be accurate and not misleading (standard 1.3.3).

What is the difference between a review and a testimonial?

A review is usually posted by the patient on a platform you do not control, such as Google. A testimonial is a patient's comment that you choose to publish, on your website, in a leaflet or in an advert. Because you select testimonials, the risk of presenting them in a misleading way is higher. Only use genuine ones, keep the patient's written consent and contact details, and do not pick only glowing comments if they do not reflect what patients say overall.

Is false advertising illegal in the UK?

Yes. Beyond the banned practices, the DMCC Act prohibits unfair commercial practices including misleading actions, such as giving false or misleading information about a product or trader. Advertising is also regulated by the Advertising Standards Authority under the CAP Code. For dental practices, claims about treatment outcomes, qualifications and prices are where most problems arise.

A compliance checklist for your practice

1. Ask every patient the same way. One review request after each visit, by text or email, with no "were you happy?" step first.
2. No incentives. No discounts, draws or freebies for reviews on Google.
3. No staff, family or friends. Ask the team not to review the practice, and ask anyone who already has to remove their review.
4. No review targets for staff. Google's policy specifically names asking staff to collect a set number of reviews.
5. Never write a review for a patient, even if they ask you to "just put something", and do not give them AI-drafted text to post.
6. Leave negative reviews alone. Reply calmly and professionally. Report a review to Google only if it breaks Google's policies. Our guide to replying to Google reviews covers how.
7. Check your website. Testimonials genuine, consented, with records kept. Any star rating you show must reflect all your reviews, not a selection.
8. Check your agency. If anyone markets the practice for you, ask in writing how they get reviews.

The honest way to get more reviews

Google says more reviews and positive ratings can help your local ranking, and it recommends replying to reviews. The honest way to get them is volume: ask every patient, every time, and make it easy with a direct link. Across 1,489 UK places, the median practice holding a Google map place had 113 reviews and a median rating of 4.8, built the slow way. Our guide to working out your review target shows how many you actually need in your town.