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Five Stars, Zero Trust: The CMA's Crackdown on Fake Reviews Hits Just Eat, Autotrader, and Three More UK Firms

On 27 March 2026, the UK's Competition and Markets Authority announced it had opened formal investigations into five businesses over allegations of fake and misleading online reviews [1]. The targets — Just Eat, Autotrader, Feefo, Dignity, and Pasta Evangelists — span food delivery, car sales, funeral services, and artisan pasta. Each faces distinct allegations, but the underlying message is the same: the CMA is deploying new enforcement powers it has never used before, and it is starting with the review ecosystem.

"Fake reviews strike at the heart of consumer trust," said CMA Chief Executive Sarah Cardell. "We're deploying our new powers to tackle some of the most harmful practices head on." [1]

What Each Company Is Accused Of

The five investigations target different parts of the review supply chain — from how reviews are gathered, to how they are moderated, to how ratings are displayed [2].

Just Eat faces scrutiny over whether its ratings system artificially inflated star ratings for certain restaurants and grocery outlets. The CMA is examining whether the platform's methodology gave consumers a misleading impression of service quality [1][3].

Autotrader and Feefo are being investigated together. Feefo, a third-party review management company, moderated reviews on behalf of Autotrader. The CMA's concern is that a number of one-star reviews were never published on Autotrader's platform and were excluded from the star ratings consumers saw — effectively suppressing negative feedback [1][4].

Dignity, the funeral services company, is accused of asking its own staff to write positive reviews about its crematoria services — a practice that, if confirmed, would constitute fabrication of reviews by company insiders [1][5].

Pasta Evangelists allegedly offered customers discounts on future orders in exchange for five-star reviews on delivery apps, without disclosing the incentive. This would qualify as undisclosed incentivised reviewing — a practice now explicitly banned under UK law [1][6].

The CMA has stressed that it "has not yet reached conclusions on whether consumer law has been breached" by any of the five businesses [1].

The Legal Framework: What Changed in April 2025

These investigations are built on powers that did not exist two years ago. The Digital Markets, Competition and Consumers Act 2024 (DMCC Act) came into force in stages, with several provisions specifically targeting fake reviews taking effect on 6 April 2025 [7][8].

Under the DMCC Act, the following are now "banned practices" — automatically deemed unfair and illegal:

  • Obtaining or posting fake reviews
  • Publishing incentivised reviews without clear disclosure
  • Hiding or suppressing negative reviews
  • Presenting star ratings that give an inaccurate picture of underlying review data [7][8]

The penalty structure is tiered. For a substantive infringement of consumer protection law, the CMA can impose fines of up to 10% of global annual turnover (or £300,000, whichever is greater) [7][9]. For breaching undertakings given to the CMA, the fine ceiling is 5% of global turnover, plus daily penalties for ongoing non-compliance. Failing to provide information or concealing evidence during an investigation can result in fines of up to 1% of turnover [1][9].

Critically, the CMA can now determine that a breach has occurred and impose these fines without going to court — a power it previously lacked for consumer protection cases [8][10].

What the Fines Could Look Like in Practice

To understand the financial exposure, consider the companies' revenues. Auto Trader Group reported annual revenue of approximately £601 million for the fiscal year ending March 2025 [11]. A 10% fine would therefore be roughly £60 million. Just Eat Takeaway.com, which operates Just Eat in the UK as part of a wider European business, reported total revenue of approximately €3.87 billion in its most recent full year, though this figure has changed following the sale of its US business Grubhub [12]. A 10% penalty on that turnover would run into hundreds of millions of euros.

Whether the CMA would impose maximum penalties in these cases is another question. The regulator has never imposed a fine under the DMCC Act's consumer protection provisions — these are its first investigations using the new powers [10].

The Scale of the Fake Review Problem

The CMA's own data suggests that 89% of UK adults use online reviews when researching products and services, and that reviews influenced an estimated £217 billion in online retail spending in 2023 [1]. At the same time, 90% of consumers report worrying about fake review content [1].

UK Consumer Review Trust (2024)
Source: CMA / GOV.UK
Data as of Mar 27, 2026CSV

A government-commissioned study analysing 2.1 million product reviews across major UK e-commerce platforms estimated that 11% to 15% of reviews in common product categories were fake [13]. Separate research found that well-written fake reviews made consumers 3.1% more likely to purchase a product, rising to 9.2% for products priced above £80 [13]. The financial harm to UK consumers from fake review text alone was estimated at £50 million to £312 million per year [13].

Research by the consumer group Which? found that fake reviews made consumers more than twice as likely to choose poor-quality products [14]. A controlled study involving nearly 10,000 UK consumers showed that when fake reviews were combined with platform endorsements like "bestseller" badges, roughly one in four participants (24.8%) chose an inferior product, compared with one in ten (10.5%) in the control group — an increase of more than 135% [13].

Harm to Small Businesses

The distortion runs in both directions. Fake positive reviews inflate ratings for businesses that game the system, while small businesses that rely on honest feedback find themselves outranked by competitors with manufactured reputations.

For car dealers on Autotrader, the allegation that negative reviews were suppressed is particularly significant. If some dealers had their one-star reviews filtered out while others did not, the competitive playing field was not level. The Automotive Management trade publication noted the CMA's interest in "car buyers' reviews of dealers on Autotrader" as a specific focus area [4].

In the restaurant sector, the problem extends beyond Just Eat. Small hospitality businesses have reported being targeted by fake-review extortion schemes, where scammers flood a business with one-star reviews and then demand payment to remove them [15]. When platforms simultaneously inflate some restaurants' ratings through algorithmic methodology — the core allegation against Just Eat — honest operators face pressure from both above and below.

No UK trade association has published a specific figure quantifying the competitive distortion caused by fake reviews on Just Eat or Autotrader. The available evidence of harm is drawn primarily from CMA-commissioned research and academic studies rather than sector-specific industry data.

The Platform Defence: Scale and Moderation Trade-offs

Both Just Eat and Autotrader operate at enormous scale. Just Eat processes millions of orders and reviews across the UK. Autotrader lists vehicles from thousands of dealers, each generating customer feedback that must be moderated.

The platforms face a genuine technical challenge: aggressive moderation can remove legitimate reviews alongside fake ones. Any automated detection system will produce false positives, penalising honest reviewers, and false negatives, letting fake reviews through. The CMA has not published an enforceable accuracy benchmark — no specific false-positive or false-negative rate that platforms must achieve [10].

An Autotrader spokesperson told ITV News the company was "cooperating fully" with the CMA and was "committed to maintaining the integrity" of reviews on the platform [3]. Just Eat similarly indicated it would work with the regulator [3].

The DMCC Act requires businesses to take "reasonable and proportionate steps" to prevent the publication of fake reviews — language that leaves room for interpretation and will likely be tested through these investigations [7]. What counts as "reasonable" for a platform processing millions of reviews is an open question that no UK regulator has yet defined with specificity.

How This Fits Into Global Enforcement

The UK is not acting in isolation. Fake review regulation has become a transatlantic enforcement priority.

In the United States, the Federal Trade Commission proposed its fake reviews rule in June 2023, finalised it in August 2024 on a unanimous 5-0 vote, and it took effect on 21 October 2024 [16]. The FTC rule prohibits buying, selling, or publishing fake reviews, suppressing negative reviews, and undisclosed insider reviews. Violations carry civil penalties of up to $53,088 per violation [16][17]. In December 2025, the FTC issued its first enforcement warning letters to ten companies under the new rule [17].

In the EU, misleading practices relating to consumer reviews are addressed through the Unfair Commercial Practices Directive, the Better Enforcement Directive, and the Digital Services Act [18]. The EU framework requires platforms to disclose how reviews are verified and prohibits publishing fake reviews, but enforcement is handled by individual member states rather than a single EU-wide body.

The UK's penalties are structured differently from the US approach. The FTC's per-violation fines can scale rapidly for platforms with millions of reviews, but the CMA's turnover-based penalties create a different kind of exposure — particularly for large companies. A 10% global turnover fine against a company the size of Just Eat Takeaway.com would dwarf any FTC per-violation penalty imposed to date. Whether the CMA will actually impose fines at or near that ceiling remains to be seen.

CMA Fake Reviews Enforcement Timeline
Source: GOV.UK / CMA
Data as of Mar 27, 2026CSV

The CMA's Track Record: Undertakings, Not Fines

The CMA's enforcement history on fake reviews follows a pattern of negotiated outcomes rather than penalties.

The regulator opened its first fake reviews investigation in June 2021, targeting Amazon and Google [19]. That investigation took years to resolve through voluntary commitments rather than fines.

Google signed undertakings in January 2025 — more than three and a half years after the probe opened — committing to enhanced processes for tackling fake reviews and a three-year reporting requirement to the CMA [20]. Amazon followed in June 2025, signing 38 separate undertakings covering fake review detection, catalogue abuse, and sanctions for businesses that game the system [21].

The CMA has not imposed a financial penalty on any major tech company for breaching UK competition or consumer protection law [22]. Previous cases against Amazon, Google, and others have all been resolved through commitments and undertakings.

This pattern raises a question: will the new DMCC Act powers actually produce fines, or will the CMA continue to prefer negotiated settlements? The legal tools are now significantly stronger, but institutional tendencies may persist.

The CMA expects to provide an update on the five new investigations by September 2026 [1]. If the Amazon and Google cases are any guide, final resolution could take considerably longer.

What Comes Next

These five investigations test whether the CMA's new powers will translate into materially different outcomes than the undertakings-based approach that characterised its first five years of fake review enforcement.

The cases cover a useful cross-section of the review ecosystem: algorithmic rating inflation (Just Eat), negative review suppression by a third-party moderator (Autotrader/Feefo), astroturfing by company employees (Dignity), and undisclosed incentivised reviews (Pasta Evangelists). If the CMA pursues each to a formal finding, the resulting guidance would establish precedent across the most common categories of review manipulation.

For businesses beyond these five, the signal is clear. The CMA's Cardell described the investigations as part of a broader "sweep of review platforms" to identify non-compliance [23]. The total number of businesses under CMA investigation for review-related practices now stands at 14, including the earlier Amazon and Google cases [10].

The £217 billion in annual UK consumer spending influenced by online reviews is not going to shrink [1]. The question is whether regulatory enforcement can keep pace with the incentives to manipulate the systems that channel it.

Sources (23)

  1. [1]
    Fake and misleading reviews: 5 businesses under CMA investigationgov.uk

    CMA announces five new consumer law investigations into fake and misleading online reviews, targeting Just Eat, Autotrader, Feefo, Dignity, and Pasta Evangelists.

  2. [2]
    Online reviews - CMA case pagegov.uk

    CMA's ongoing case tracker for online reviews enforcement, covering investigations from 2021 to present.

  3. [3]
    Just Eat and Autotrader among companies under investigation over fake reviewsitv.com

    ITV News report on CMA investigations, including company responses and details of specific allegations against each firm.

  4. [4]
    CMA to examine car buyers' reviews of dealers on Autotraderam-online.com

    Automotive Management reports on CMA probe into how car buyer reviews of dealers are handled on the Autotrader platform.

  5. [5]
    Just Eat under UK probe over 'misleading' reviewsrte.ie

    RTÉ coverage of the CMA's investigation into Just Eat and four other companies over fake and misleading online reviews.

  6. [6]
    Autotrader & Just Eat investigated in fake review crackdownbusinesscloud.co.uk

    BusinessCloud reports on the CMA's crackdown covering Pasta Evangelists' alleged incentivised five-star review scheme.

  7. [7]
    Consumer reviews: new prohibitions under the DMCC Act 2024weightmans.com

    Legal analysis of the DMCC Act's banned practices for online reviews, including fake reviews, undisclosed incentives, and suppression of negative feedback.

  8. [8]
    CMA Cracks Down on Fake and Misleading Online Reviews: Five New Investigations Launchedwiggin.co.uk

    Legal analysis noting the CMA no longer requires court involvement to determine breaches and impose fines under the DMCC Act.

  9. [9]
    Digital Markets, Competition and Consumers Act 2024 explained: The CMA's new enforcement toolkitwomblebonddickinson.com

    Detailed breakdown of DMCC Act penalties: up to 10% of global turnover for infringements, 5% for breaching undertakings, 1% for obstructing investigations.

  10. [10]
    The UK Consumer Law Revolution - CMA targets consumer reviewslewissilkin.com

    Lewis Silkin analysis noting these are the CMA's first formal enforcement actions under enhanced DMCC Act consumer protection powers, bringing total investigated businesses to 14.

  11. [11]
    Auto Trader Group Revenuecompaniesmarketcap.com

    Auto Trader Group reported annual revenue of approximately £601 million for fiscal year ending March 2025.

  12. [12]
    Just Eat Takeaway Revenuecompaniesmarketcap.com

    Just Eat Takeaway.com reported total revenue of approximately €3.87 billion, with figures affected by the sale of Grubhub.

  13. [13]
    Investigating the prevalence and impact of fake reviewsgov.uk

    Government-commissioned research estimating 11-15% of UK online reviews are fake, with annual consumer harm of £50-312 million from fake review text alone.

  14. [14]
    The real impact of fake reviewswhich.co.uk

    Which? research finding fake reviews make consumers more than twice as likely to choose poor-quality products.

  15. [15]
    Small businesses hit by global scam of fake negative Google reviewsconsumeraffairs.com

    Reports on fake negative review extortion schemes targeting small businesses, with one contractor's rating dropping from 5 stars to 3.6.

  16. [16]
    FTC Announces Proposed Rule Banning Fake Reviews and Testimonialsftc.gov

    FTC proposed its fake reviews rule in June 2023, finalised August 2024 on a 5-0 vote, effective October 2024.

  17. [17]
    FTC Issues Warning Letters for Violations of Consumer Reviews Ruleinsideprivacy.com

    In December 2025, the FTC issued its first enforcement warning letters to 10 companies, with violations carrying penalties of up to $53,088 per violation.

  18. [18]
    Parliamentary question: Tackling fake reviews and building trust in digital serviceseuroparl.europa.eu

    European Parliament question on how fake reviews are addressed under the Unfair Commercial Practices Directive and Digital Services Act.

  19. [19]
    CMA to investigate Amazon and Google over fake reviewsgov.uk

    CMA opened its first fake reviews investigation in June 2021 targeting Amazon and Google over whether they did enough to detect and remove fake reviews.

  20. [20]
    CMA secures important changes from Google to tackle fake reviewsicpen.org

    In January 2025, Google signed undertakings committing to enhanced fake review detection processes and a 3-year CMA reporting requirement.

  21. [21]
    Amazon gives undertakings to CMA to curb fake reviewsgov.uk

    In June 2025, Amazon signed 38 undertakings covering fake review detection, catalogue abuse prevention, and sanctions for gaming the system.

  22. [22]
    Amazon gets a late invite to the CMA enforcement partylinklaters.com

    Analysis noting the CMA has yet to impose a financial penalty on any major tech company, instead resolving cases through commitments and undertakings.

  23. [23]
    From five stars to fines: the risks of fake reviews in the UKashurst.com

    Ashurst analysis of DMCC Act enforcement, noting a three-month grace period from April 2025 and CMA sweep of review platforms to identify non-compliance.