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What tougher review enforcement means for commerce reviews customer interviews

A practical listicle on commerce reviews customer interviews: inclusion rules, participant data duties and how interview evidence compares with review exports.

What to take away

  • The Digital Markets, Competition and Consumers Act 2024 lets the CMA rule a review practice unfair and fine the business without going to court first.
  • Four practices are bannedfake reviews, undisclosed incentives, review gating, and misleading presentation.
  • Write the inclusion rule before recruitingone purchase window, one market, a minimum number of reviews read or written, and at least two buyers who never reviewed.
  • Interviews explain motive and trust; exported review data shows volume and wording. Fund both from one budget line where the decision needs both.

What the DMCC Act 2024 and CMA enforcement require of review collection

The Act puts review practices inside the CMA's unfair commercial practices powers. The regulator can investigate and decide that a breach has occurred.

The CMA can fine up to 10 per cent of global turnover for consumer protection breaches, without a court order.

Four review practices are banned:

  • Writing, commissioning or hosting fake reviews.
  • Rewarding a review without disclosing the reward.
  • Inviting only customers likely to be positive, known as review gating.
  • Presenting reviews in a way that misleads buyers, including burying negative ones.

The older misleading omissions test still applies. Regulation 6 of the Consumer Protection from Unfair Trading Regulations 2008 makes silence misleading when it changes a buyer's decision.

For interviews, say who paid for the conversation and what it was for. The commerce reviews advertising rules in England article covers where ASA codes sit alongside CMA duties if you reuse quotes as marketing.

Map each interview rule to an enforcement point

Map interview rules to enforcement

Interview design choiceEnforcement point it answers
Recruit critics as well as fansAvoids review gating
Pay an incentive and disclose itUndisclosed incentives
Ask open prompts, no preferred answerMisleading presentation
Keep recruitment notesEvidence of a fair method

Run interviews as research, not a hunt for quotable praise. A prompt that hints at the answer produces material you should not publish as a customer view.

Set your inclusion criteria before you recruit

State four things in writing before you approach anyone:

Set inclusion criteria first

  • A purchase window, such as the last six months.
  • One market, so answers stay comparable.
  • A minimum number of reviews read or written in that period.
  • At least two people who bought but never left a review.

Participant inclusion criteria

  • Purchase windowlast six months
  • One market for comparable answers
  • Minimum reviews read or written
  • Two buyers who never reviewed

That last rule keeps you clear of gating. The commerce reviews audience research guide for England sets out the full scoping method from recruitment to write-up, so you do not rebuild the brief next quarter.

Ask questions that answer the enforcement test

Rating averages record what happened. They rarely explain why, or which sentence changed a buyer's mind. Build prompts from your own review text: quote a phrase and ask what the writer meant; read a low-rating comment without its stars and ask what would have helped.

Ask where buyers looked before they ordered, and who they told afterwards. Then ask what nearly stopped them buying, and what they checked after delivery. Note the words people use for your product, because they feed review request emails better than a score does.

Where an England brief changes the rule and where it does not

Consumer protection and data duties apply across the UK. An England-only panel changes whose experience you hear, not which duties you follow. Recruitment creates personal data from the first enquiry, so the ICO's data protection principles cover the lawful basis, retention period and accuracy checks for notes and recordings.

Example: a Leeds-only panel

Eight Leeds buyers aged 25 to 34 change recruitment and travel, not compliance. You still need a lawful basis, a retention period and disclosure of any incentive, as a UK-wide panel would.

Segments still decide who you invite. The commerce reviews buyer personas in England page gives a starting set to map onto your inclusion list.

Compare methods before you commit a budget

Set the decision first, then pick the cheaper method that fits it.

Compare methods before budgeting

Customer interviews

Best for
Motive, trust and wording
Time to first insight
Two to four weeks to recruit
Main cost
Incentives and moderation
Sample size
Small and purposive
Main risk
Leading questions

Exported review data

Best for
Volume, ratings and timing
Time to first insight
Same day, if you hold access
Main cost
Analyst time
Sample size
Whatever your platforms hold
Main risk
No explanation of cause

Twelve interviews at £50 each is about £600 before moderation time. That figure is illustrative.

Common questions

How many interviews should I run?

No fixed number. Stop when two conversations in a row add no new reason or complaint.

Do I need consent to record the calls?

Yes. State what the recording is for and how long you will keep it. Publishing a quote is a separate purpose, so ask for that separately.

Does any of this change in Scotland, Wales or Northern Ireland?

No. The DMCC duties, the misleading omissions test and the data rules apply across the UK. Your audience changes, so note where participants are based.

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