DMCC Act 2024 one year in: enforcement patterns emerging

What the Act actually changed on reviews

Under the DMCC Act, submitting a fake review is prohibited, commissioning a fake review is prohibited, and — the biggest shift — publishing fake reviews without taking reasonable steps to detect and remove them is prohibited for platforms.

The 'reasonable steps' standard is the fulcrum of the regime. It is deliberately open-textured, which gives the CMA room to raise the bar as detection technology improves. What was reasonable in 2024 is not automatically reasonable in 2026.

Incentivised reviews are not banned outright, but they must be clearly disclosed at the point the reviewer is invited and at the point the review is displayed. Undisclosed incentivisation is treated the same as fabrication in the CMA's enforcement priorities.

The Act also introduced a formal role for consumer bodies in the enforcement chain, and gave the CMA the power to impose civil penalties directly — up to 10% of global turnover for the most serious platform-level breaches. The direct-penalty power is what has changed platform behaviour fastest.

The enforcement picture at 12 months

The CMA has been deliberate rather than dramatic. Public enforcement in the first year has focused on precedent-setting cases in three sectors — home improvement, cosmetic clinics and short-let property.

The pattern is intentional: establish precedent in sectors that most concern consumers, publish detailed reasoning, and let the market self-adjust. This is close to how the CMA handled early DMA-adjacent competition cases, and it appears to be working — the platform side of the ecosystem has moved substantially in the first year.

The 31 warning letters to platforms are the more interesting number. They signal that the CMA is treating platform diligence as the primary lever for scale, with individual-business fines used only where commissioning is unambiguous.

Public CMA review-related enforcement actions

9

Warning letters issued to platforms

31

Businesses fined for commissioning

14

Median fine size

£42,000

Largest platform-level penalty in the period

£2.3m

Cross-border referrals to the FTC

5

What 'reasonable steps' means in practice

The CMA has not defined 'reasonable steps' exhaustively, but the pattern of enforcement letters gives a clear picture of the current baseline. Missing any of the following is now high-risk for platforms and, by extension, for the businesses they host.

The gap column above is not hypothetical — every item appears in at least one 2024–2025 warning letter. Platforms that clear the baseline in every row are essentially outside the enforcement risk zone; platforms that miss two or more are visibly exposed.

For businesses using multiple platforms, the practical takeaway is that platform choice is now a compliance decision, not only a marketing one. Being listed on a platform that fails the baseline exposes your reviews to being caught up in a broader enforcement action.

What UK businesses should do now

Regardless of size, the sensible posture in year two of the Act is to align workflow to the baseline and use the alignment as a marketing asset. Compliance and conversion pull in the same direction here.

1. 1Audit your review pipeline: for each review, can you produce, in writing, the evidence class and the verification tier? If not, move to a platform that publishes tiers explicitly.
2. 2Never incentivise without disclosure. If you offer a discount for a review, say so in the invitation, and require the platform to display an 'incentivised' label on the resulting review.
3. 3Formalise your reply SLA. Written 48-hour reply target, an escalation path for reviews left unanswered, and a monthly reply-rate metric in the operator dashboard.
4. 4Engage disputes rather than deleting. Every use of the dispute workflow builds an evidence trail that protects you if a broader enforcement action lands in your sector.
5. 5Refuse pay-to-suppress services categorically, and archive the refusal. If a 'reputation management' firm offers to remove a one-star review for a fee, that offer is enforcement bait — decline in writing and keep the record.
6. 6Publish your own review policy on your site. A short public page saying 'we use ScoreReview UK, our reviews are verified at Tier 3+ by default, we do not remove reviews for commercial reasons' is a differentiator in 2026.

“The DMCC Act's real innovation is that it treats review integrity as a platform-diligence question, not just a per-review one. That shift is what has moved the market in twelve months more than the fines themselves.”

Summary and what to watch in year two

The first year of DMCC enforcement has been a controlled ramp — enough precedent to move the market, not so much that platforms have panicked. Year two is likely to see the CMA raise the 'reasonable steps' baseline as detection technology matures, and to widen enforcement into sectors that were quiet in the first year.

Businesses that align now will find the baseline moves toward what they are already doing, which is a rare position to be in against a moving regulatory target. Businesses that continue with ad-hoc processes will find themselves increasingly exposed as the baseline shifts.

The DMCC Act is not a burden — it is finally the regulatory scaffolding the honest majority of UK businesses have needed to compete on level ground with operators who used fake reviews to cut corners. Twelve months in, it is starting to work.