You can ask customers for honest reviews, and UK law does not ban every incentive: it bans fake reviews and concealed ones. Google goes further and bans incentivised reviews outright, disclosed or not.
That leaves a simple default: invite everyone consistently, offer no reward, let them say what they like. Build it into your Google Business Profile routine.
The rules started on 6 April 2025
The Digital Markets, Competition and Consumers Act 2024 puts the unfair-trading rules in Part 4, Chapter 1, with Schedule 20 listing practices unfair in all circumstances. They came into force on 6 April 2025, and the CMA’s initial three-month softer-enforcement period ended that July, so no adjustment period remains. (Commencement regulations, CMA)
These practices are banned
Schedule 20, paragraph 13 covers “a consumer review that conceals the fact it has been incentivised”. It prohibits:
- Submitting or commissioning fake reviews, whether invented praise for yourself or invented attacks on competitors.
- Submitting or commissioning reviews that conceal an incentive.
- Publishing reviews or ratings misleadingly.
- Publishing without necessary, reasonable and proportionate steps to prevent and remove banned content.
The statute names suppressing negative reviews, and giving positive ones greater prominence, as examples of misleading publication. A small reviews page earns no exemption.
These requests can be allowed, with conditions
A genuine review can be rewarded where the platform permits it and the incentive is prominent. Tell the reviewer to disclose it, preserve that disclosure when you publish, and do not bury it behind a link. The CMA says an advert label will usually be needed: “Ad: I received a £10 voucher for leaving this honest review.” (CMA guidance, paragraphs 3.5 to 3.7)
Prize draws carry a nuance: CMA guidance says a chance of a reward, with no guaranteed benefit, is unlikely to count as commissioning under this ban. It does not license misleading presentation or override platform rules. (CMA guidance, footnote 8)
Google has a stricter rulebook
Google’s policy bans rewards for reviews, incentives to revise or remove negative ones, and selectively soliciting positive ones. Disclosure cures none of it, so a prize draw aimed at Google reviews has to go.
It also bans pressuring customers on the premises and setting staff review quotas. Invite them after the job, and measure whether the process reaches people consistently rather than chasing five-star counts. That is better local SEO anyway.
Stop filtering the invitation by satisfaction
Consider a survey that routes happy customers to Google and unhappy ones to a private form. You are choosing who gets the public invitation by their likely verdict. That is review gating, and it sits squarely inside Google’s ban on selective solicitation.
This is not only a Google problem. Filtering who gets asked shapes what ends up on public display, which is what the UK misleading-publication limb covers, so gating risks engaging both. (CMA guidance)
Use the same invitation for customers with comparable completed jobs. Keep a complaints channel open to everyone, and never make resolving a complaint conditional on silence.
Your own site needs the same care. Calling a page “testimonials” does not remove misleading-publication risk: selected praise must not pose as a representative feed or prop up a rating that excludes criticism. Judge the impression the page creates, not whether each quotation is authentic. (Schedule 20)
The £300,000 ceiling is not a typical fine
Section 182(6) sets the maximum at the higher of £300,000 or 10% of turnover, and the CMA can impose it without a court judgment, after its investigation and representations process and subject to appeal. (CMA enforcement guide) On relevant worldwide turnover:
| Turnover | 10% | Higher statutory ceiling |
|---|---|---|
| £300,000 | £30,000 | £300,000 |
| £1 million | £100,000 | £300,000 |
| £3 million | £300,000 | £300,000 |
| £5 million | £500,000 | £500,000 |
The crossover is £3 million, so below it “only 10% of turnover” understates the ceiling, and group turnover can count. (Section 204) A maximum is not a likely outcome: the CMA weighs seriousness and corrective action, and can accept undertakings instead. But there is no guaranteed warning first.
Enforcement has moved beyond guidance
The CMA has opened investigations into several businesses’ review practices, one concerning alleged undisclosed discounts for five-star reviews. Opening an investigation is not a finding; the CMA’s case page records the current status.
None of it establishes a typical penalty for a small trader. An earlier CMA sweep sent advisory letters to 54 businesses and about 90% improved their policies, so a corrective route exists. (CMA update) In practice a complaint in England or Wales reaches Trading Standards through Citizens Advice, with Advice Direct Scotland and Consumerline doing the same job in Scotland and Northern Ireland. Or it reaches the platform. Either way the realistic first consequence is reviews removed and your process changed.
The voucher budget can buy a temporary rating
Issue £10 review vouchers and suppose 20 are redeemed in a year. That is £200, and every one of those reviews is a liability: concealing the reward breaches the rules, and on Google the incentive breaches policy either way.
For illustration, 40 genuine reviews averaging 4.2 stars plus those 20 five-star ones average 4.47. Remove the 20 and you are back to 4.2, so the £200 bought 0.27 of a star on a rating the platform can withdraw at any time. Example arithmetic, not Google’s displayed score.
What “reasonable and proportionate” looks like for a small firm
The duty to take reasonable and proportionate steps is the part small firms find hardest, because it scales with your circumstances instead of arriving as a checklist. For a firm with a few dozen reviews a year, proportionate is modest, and mostly about being able to show your working later:
- Name one person responsible for reviews and complaints, even if it is you.
- Write the process down in a paragraph: who gets asked, when, in what words, and what happens to a complaint. That paragraph is your reviews policy.
- Ask every comparable customer, not the ones you expect to be happy, and keep the send list.
- Offer no reward on Google. Where a channel permits one, disclose it in the review itself.
- Report reviews that look fake, whether they flatter you or attack you, and note that you did.
- Check your testimonials page against the full picture once a year.
- Audit what is already running: stop Google incentives, fix or remove undisclosed ones elsewhere, and check any rating built on them. Outsourcing the feed does not outsource the responsibility.
Nobody expects a two-van firm to run a verification team. They do expect you to have thought about it once, and to be able to say what you decided. (CMA publisher guide)
Use a request that leaves the verdict to the customer
“Thank you for choosing [business]. If you would like to share your experience, you can leave an honest review here: [review link]. Please describe your experience in your own words, whether positive or negative. There is no reward for reviewing, and leaving a review is entirely optional.”
Replace the brackets and use it for everyone. No wording saves a process that only sends it to satisfied customers.
