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reviews · 10 min read · 14 July 2026

Review Gating and UK Law: What You Can and Can't Do

Review gating breaches Google policy and now risks CMA fines under the DMCC Act. What UK businesses can and cannot do when asking for reviews.

Jacob Horgan, Founder, Irvale Studio
Jacob Horgan
Founder, Irvale Studio
A UK business owner checking consumer law compliance documents at an office desk.

Review gating used to sit in a grey area. Plenty of UK businesses ran it without thinking twice, often because their review software did it by default. That era is over. Google has banned the practice in its content policy for years, and since April 2025 UK consumer law has caught up with teeth of its own. This guide sets out what review gating actually is, where the legal lines now sit, and how to run a review process that grows your rating without inviting a letter from the Competition and Markets Authority.

What is review gating?

Review gating is the practice of filtering customers by sentiment before inviting them to leave a public review. A business asks each customer whether their experience was good or bad, then sends happy customers a link to Google or Trustpilot while routing unhappy customers to a private feedback form that is never published. The result is a public rating built only from people the business already knew were satisfied.

The mechanics vary. Some firms use a thumbs up or thumbs down email. Others use a star widget where four and five stars reveal the Google link and one to three stars open a complaint form. Some review platforms sold to UK small businesses have offered this flow as a feature, marketed as reputation protection.

Whatever the wrapper, the effect is the same. The published reviews stop being a fair sample of customer experience and become a curated highlight reel. That is the specific harm both Google and UK law now target.

Is review gating illegal in the UK?

For most implementations, yes. Since 6 April 2025 the Digital Markets, Competition and Consumers Act 2024 has made publishing consumer reviews in a misleading way a banned practice under UK consumer law, and legal analysis from CMS confirms this covers suppressing negative reviews and cherry-picking positive ones. A gating flow exists to do precisely that, so a UK business running one is exposed.

Before the Act, misleading review practices could already be challenged under older consumer protection regulations, but enforcement was slow and rare. The DMCC Act changed the enforcement model as much as the rules. According to CMS's analysis of the new regime, the banned practices cover three areas: fake and concealed incentivised reviews, publishing reviews in a misleading way, and providing services that facilitate any of it.

The second category is the one that catches gating. You do not need to have written a single fake review to breach it. Deciding which genuine reviews see daylight, based on whether they flatter you, is enough.

The CMA published detailed guidance on the fake reviews regime in April 2025, just before the rules took effect, and it committed to a supportive rather than punitive stance for the first three months. That grace period is long gone.

What does Google's policy say about review gating?

Google's Maps user generated content policy prohibits merchants from discouraging or prohibiting negative reviews, and from selectively soliciting positive reviews from customers. That second clause is a direct description of review gating. The policy also bans offering incentives such as payment, discounts, or free goods in exchange for posting, editing, or removing a review.

The exact wording in Google's contribution policy is worth reading in full, because it is broader than many businesses assume. Merchants must not "discourage or prohibit negative reviews, or selectively solicit positive reviews from customers", and should not pressure customers to leave ratings while still on the premises.

Enforcement is real, if inconsistent. Google states that violations can lead to actions ranging from suspension of account privileges to account termination. In practice, businesses caught gating have seen reviews removed in bulk, including legitimate ones, and in more serious cases have lost their Business Profile visibility. If your profile is not set up correctly in the first place, start with the basics of Google Business Profile setup and verification before worrying about volume.

What does the DMCC Act actually ban around reviews?

The Act bans three things. First, fake reviews and concealed incentivised reviews, meaning reviews not based on genuine experience or reviews that hide the fact they were rewarded. Second, publishing consumer reviews in a misleading way, which includes suppressing negative reviews, cherry-picking positive ones, reusing outdated reviews, and review hijacking. Third, offering services that commission fake reviews or help evade detection.

The scope is wide. As CMS notes, the rules apply to anyone publishing or providing access to reviews, including marketing agencies, influencers, review platforms, and the businesses themselves. There is no small business carve out, although the CMA has said compliance expectations scale with circumstances and risk.

Two points deserve emphasis for UK small businesses. Incentivised reviews are not banned outright, but concealing the incentive is, and Google's stricter policy bans the incentive entirely on its platform. And the misleading publication ban applies to how you display reviews on your own website too, not just what you solicit on third party platforms. A testimonials page that quietly omits every critical comment you have received through the same channel is a risk, not a marketing asset.

What penalties can UK businesses face?

The CMA can now fine businesses directly for consumer law breaches, with a maximum penalty of 10 percent of global turnover, a power it confirmed when announcing its first review investigations in March 2026. Alongside the regulatory risk, Google can remove gated reviews and suspend Business Profiles, which for a local business is often the more immediate commercial damage.

The scale of the money involved explains the regulator's interest. The CMA's March 2026 announcement notes that reviews were used by 90 percent of consumers and contributed to the £217 billion spent in online retail markets in 2023, and cites Which? research finding that 89 percent of UK adults use online reviews when researching a product or service, according to the official investigation notice.

89%of UK adults use online reviews when researching a product or service
Source: Which?, cited by CMA, March 2026
£217bnspent in online retail markets in 2023, spending that reviews contributed to
Source: CMA, March 2026
10%of global turnover, the maximum CMA fine for a breach
Source: DMCC Act 2024

For most small firms, the realistic sequence is not a nine figure fine. It is an information request, an undertaking to change practice, and public naming. All of it avoidable by running a clean process from the start.

Is the CMA actually enforcing this?

Yes. On 27 March 2026 the CMA announced its first five consumer law investigations under the new regime, naming Autotrader, Feefo, Dignity, Just Eat and Pasta Evangelists. The Autotrader and Feefo cases concern whether one star reviews were left unpublished and uncounted in star ratings, which is the publication side of the same behaviour review gating produces.

The detail in the CMA's announcement is instructive because each case maps to a different banned practice. Dignity is suspected of asking staff to write positive reviews of its crematoria services. Just Eat's ratings system is suspected of inflating certain restaurants' star ratings. Pasta Evangelists is suspected of offering discounts for five star reviews without disclosure.

None of these investigations has concluded, and being investigated is not a finding of guilt. But the direction is unambiguous. Review manipulation moved from a platform policy problem to a named and shamed regulatory one within a year of the rules taking effect.

What can you legally do when asking for reviews?

You can ask every customer for a review, remind them once or twice, make the process easy with a direct link or QR code, and respond publicly to whatever they write. The single non-negotiable rule is that the invitation must go to everyone through the same route, without sentiment filtering, incentives, or pressure applied on the premises.

A compliant process is not complicated, and it still works. Ask at the moment of highest satisfaction, usually right after the job is done or the product has landed. Send the same short message to every customer with a direct review link. Follow up once after a few days. Reply to every review, good and bad. There is a full walkthrough of this in the guide to getting more Google reviews ethically in the UK, and the mechanics can be automated end to end, as covered in automating Google review requests in about 30 minutes.

What you cannot do: filter by sentiment before sending the link, offer discounts or gifts for reviews on Google, draft the review text for customers, have staff or family post reviews, or ask customers to remove negative reviews as a condition of a refund.

The uncomfortable truth is that gating never fixed the underlying problem anyway. It hid unhappy customers from Google while leaving them unhappy, and often louder elsewhere.

Can you still handle unhappy customers before they review you?

Yes, and you should. Service recovery is legitimate. You can survey customers privately, spot dissatisfaction early, call them, and fix the problem before they ever think about Google. What you cannot do is make the public review invitation conditional on the survey result. Run recovery and review requests as two separate, unconditional workflows.

This is the distinction that trips up most well intentioned owners. Asking "how did we do?" is fine. Using the answer as a gate is not.

A clean pattern looks like this. Every customer receives a satisfaction survey. Anyone flagging a problem gets a phone call within a day and a genuine fix. Separately, on its own schedule, every customer receives the same review invitation. Some of the people you helped after a complaint will leave you a strong review precisely because you fixed things, and those recovery stories tend to be the most persuasive reviews on a profile.

If a customer posts something false or defamatory, you are not helpless either. Google allows reporting of reviews that breach its content rules, and UK defamation law exists for genuinely false statements of fact. Neither route requires you to suppress honest criticism.

How do you build a compliant review process that still grows your rating?

Ask everyone, ask quickly, make it effortless, and reply to everything. Businesses that send a same day review request to every customer, with a direct link and one polite reminder, consistently grow both volume and average rating without touching a single grey area practice, because most customers who bother to respond are satisfied ones anyway.

Volume is the honest lever gating pretended to be. A profile with 200 reviews at 4.6 beats a profile with 30 reviews at 4.9 in most local markets, both for conversion and for local ranking, and the only way to get volume is to ask everyone, systematically.

Practical steps for a UK small business. Put the review ask into your job completion workflow so it never depends on someone remembering. Use the short review link from your Business Profile, or a QR code on invoices and van signage. Keep the message plain and personal, one sentence of thanks and the link. Reply to every review within a couple of days, especially the critical ones, because your reply is read by every future customer. And document the process in writing, because if the CMA or a platform ever asks questions, a written policy showing you invite all customers equally is your best evidence.

If you would rather have this built once, properly, and wired into the rest of your customer follow up, a done for you review management service handles the requests, monitoring, and responses on a compliant footing.

Next stepGet a compliant review engine built for youSystematic review requests, monitoring and responses, wired into your revenue system.

The rules are stricter than they were, but they only really punish the shortcut. A business that asks every customer, fixes real problems fast, and answers its critics in public has nothing to fear from the DMCC Act, and usually ends up with the better rating anyway.

Common Questions

Review Gating and UK Law — FAQ

Is review gating illegal in the UK?

It is now firmly in illegal territory for most implementations. Since 6 April 2025, the Digital Markets, Competition and Consumers Act 2024 has treated publishing consumer reviews in a misleading way, which includes suppressing negative reviews and cherry-picking positive ones, as a banned practice under UK consumer law, according to analysis by law firm CMS. A classic gating flow, where happy customers are routed to Google and unhappy customers are routed to a private form, is designed to skew the published picture of customer sentiment, which is exactly what the ban targets. Even before the Act, gating breached Google's Maps content policy, which prohibits selectively soliciting positive reviews. The safe position for a UK business is simple. Ask every customer for a review through the same public route, regardless of how you think they will rate you.

What is the penalty for breaching the fake reviews rules?

The Competition and Markets Authority can now fine businesses directly, without going through the courts first, for breaches of consumer protection law. The maximum penalty is 10 percent of global turnover, a figure confirmed in the CMA's March 2026 enforcement announcement. For a small business the realistic first consequence is unlikely to be a headline fine. It is more likely to be an information request, a required undertaking to change your review process, and the reputational cost of being named publicly. There is also a parallel commercial penalty from Google, which can remove reviews it believes were gated, and in serious cases suspend a Google Business Profile entirely. Losing your review count and local ranking often hurts a small firm faster than any regulatory process would.

Can I still ask customers if they were happy before requesting a review?

You can ask about satisfaction, and you should, because feedback surveys are a legitimate and useful tool. The line is crossed when the answer to that question determines who gets invited to review you publicly. If a five star response triggers a Google review link and a two star response triggers only a private feedback form, that is gating, and it falls foul of both Google's policy on selectively soliciting positive reviews and the DMCC Act's ban on publishing reviews in a misleading way. The compliant pattern is to separate the two activities. Run internal satisfaction surveys whenever you like, and separately send every customer the same public review invitation. You can still prioritise service recovery for unhappy customers, as long as the public invitation is not withheld from them.

Does the DMCC Act apply to small businesses or just big platforms?

It applies to businesses of all sizes. The banned practices around fake and misleading reviews cover anyone who commissions, writes, or publishes consumer reviews, from national marketplaces down to a sole trader plumber with a Google Business Profile. Law firm CMS notes that the rules reach professional reviewers, marketing companies, and the businesses themselves, though the CMA has said compliance expectations will differ based on circumstances and risk. In practice the CMA's first named investigations, announced on 27 March 2026, targeted larger firms including Autotrader, Feefo, Just Eat, Dignity and Pasta Evangelists. Small businesses are not the priority target, but they get no exemption, and the same conduct that got large platforms investigated, suppressing negative reviews and undisclosed incentives, is common in off the shelf review software aimed at small firms.

Can I offer a discount or freebie in exchange for a Google review?

No, not without breaking at least one set of rules, and usually two. Google's Maps content policy prohibits offering incentives such as payment, discounts, or free goods and services in exchange for posting a review, and that prohibition applies even if you ask for an honest review rather than a positive one. Under the DMCC Act, concealed incentivised reviews are a banned practice, so a review that was rewarded without that being disclosed is unlawful in the UK. One of the CMA's first investigations, into Pasta Evangelists, concerns exactly this, the suspicion that discounts were offered for five star reviews without disclosure. If you want to reward feedback, reward participation in a private survey instead, and keep public review requests incentive free.

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