Commerce reviews disclosure policy explained for England

What to take away

A commerce reviews disclosure policy is a written internal rule that says how your business labels reviews, ratings and user-generated content so shoppers know what they are reading.
In England, the Consumer Protection from Unfair Trading Regulations 2008 ban misleading commercial practices, including fake or undisclosed incentivised reviews, and the Digital Markets, Competition and Consumers Act 2024 now bans fake and undisclosed incentivised reviews and allows the CMA to enforce directly.
The ASA applies the CAP Code to reviews and endorsements used as advertising, and the CMA enforces the consumer protection rules.
UK GDPR governs personal data in reviews, so your policy must cover consent, retention and takedown.
The clause list and decision table below show what to include and the safest default.

Why a written policy matters in England

The Consumer Protection from Unfair Trading Regulations 2008 make publishing fake reviews, or misleading shoppers about whether a review is genuine, a breach. The Digital Markets, Competition and Consumers Act 2024 tightened that regime: it added fake and undisclosed incentivised reviews to the list of banned practices and gave the CMA the power to enforce directly rather than only through the courts. The CMA's published guidance for businesses — its advice on online reviews and its "Hidden ads: being clear with your audience" material — sets out how it applies those rules.

These rules are UK-wide, so a business in England, Wales, Scotland or Northern Ireland works to the same standard. Only the enforcement route and the courts differ.

Map every review placement

Product pageswho supplies content
Category pagesmoney or gift involved
Email campaignsdisclosure before review
Social postslabel before shopper reads
Note if value changed hands

A written policy gives your team one reference point. A marketplace seller or affiliate partner cannot slip an unlabelled incentive past you.

Map every place a review or rating appears: product pages, category pages, email campaigns and social posts. For each placement, note who supplies the content and whether money, a free product or a discount changed hands. If value moved, the disclosure must be obvious before the shopper reads the review, not buried in a footer.

What the ASA expects

The Advertising Standards Authority treats reviews and endorsements in marketing communications as advertising and applies the CAP Code to them. Rule 2.1 requires marketing communications to be obviously identifiable as such, and rule 2.3 prohibits claiming or implying that the marketer is acting as a consumer. The ASA's AdviceOnline library carries the detailed entries — on recognising ads, including social media and influencer marketing, and on testimonials and endorsements. The commercial relationship must be clear, and the label prominent enough for a reasonable shopper to understand.

Approved vs banned label wording

Use

Paid partnership: "paid promotion" or "ad"
Placement: Before the content
Gifted product: State product was gifted
Clarity: Prominent for shoppers

Avoid

Paid partnership: "in collaboration with"
Placement: After the content
Gifted product: Leave incentive unmentioned
Clarity: Buried in hashtags

For a paid partnership, write "paid promotion" or "ad" before the content, not after it.

Your policy should name the exact label wording your team may use, and ban vague phrases such as "in collaboration with" unless the commercial nature is also stated. A gifted product needs a clear label even when no cash changed hands.

Data protection duties for UGC

Reviews often contain personal data, including names, photos or order details. The ICO's UK GDPR guidance and resources explains the lawful basis, storage limitation and individual rights you must respect. Most businesses that process personal data for reviews must also register with the ICO and pay its annual data protection fee, and their details appear on the ICO's register of fee payers. Your policy should state how long you keep review data, how a reviewer withdraws consent, and who handles a deletion request.

Build a takedown route into the policy: if a reviewer asks for removal, log the request, confirm the outcome and remove it within your stated window.

If you syndicate reviews to third parties, say whether deletion propagates there. For how these duties sit alongside advertising rules, see our guide to UK review rules and compliance.

What the policy must contain

A workable policy is short and specific. Cover these clauses:

Scope.The brands, marketplaces, affiliate partners and social accounts it covers.
Definitions.What counts as a review, a rating, an incentive, a gift and a paid partnership.
Approved labels.The exact wording your team may use — "ad" and "paid promotion" before the content — and the vague phrases it may not use on their own, such as "in collaboration with".
Placement.That the label appears before the review or post is read, in the same language as the content.
Incentives.How discounts, free products, prize draws and review gating are recorded, approved and signed off.
Moderation.How you detect, remove and record fake or misleading reviews.
Data protection.The lawful basis, the retention period, consent withdrawal and deletion requests, including for syndicated reviews.
Complaints.The internal route, the regulator routes and the certified ADR provider you point shoppers to.
Ownership and review.Who owns the policy and how often it is checked against current CMA, ASA and ICO guidance.

Handling complaints and redress

Shoppers who believe a review is fake or misleading can complain to the platform, to the CMA or to a certified alternative dispute resolution (ADR) provider. ADR for consumer disputes is certified under the Alternative Dispute Resolution for Consumer Disputes (Competent Authorities and Information) Regulations 2015, and schemes such as Retail ADR and the Centre for Effective Dispute Resolution (CEDR) handle retail and consumer cases. GOV.UK's CMA help for consumers sets out the routes available when a shopper wants redress. Give your policy an internal complaint route so issues are resolved before they escalate.

Record every complaint, the review in question and the action taken. If you remove a review, keep the original content and the reason on file. That record protects you if a regulator later asks how you applied your policy.

Decision table

Choose

Paid influencer post: Clear "ad" label before content
Free product for review: State product was gifted
Customer photo in UGC: Written consent and retention limit
Negative review: Publish with a reply
Syndicated reviews: Confirm deletion propagates

Avoid

Paid influencer post: Burying disclosure in hashtags
Free product for review: Leaving the incentive unmentioned
Customer photo in UGC: Reusing photos indefinitely
Negative review: Deleting without a logged reason
Syndicated reviews: Assuming partners remove content

Common questions

Does an incentivised review always need a label?

Yes, if the incentive could affect how a shopper views the review. The label must be clear and appear before the review content.

How long can we keep review data?

Set a retention period that matches your purpose and delete data when it expires. The ICO's UK GDPR guidance explains storage limitation in more detail.

Who enforces fake review rules in England?

The CMA enforces consumer protection rules, including the ban on fake and undisclosed incentivised reviews in the Digital Markets, Competition and Consumers Act 2024, and the ASA covers advertising claims. Shoppers can also complain through the routes on GOV.UK.

Is this legal advice?

No. This is general guidance. Individual cases need a qualified adviser, and you should check current regulator guidance before changing your policy. For how the rules apply in England, see our guide to commerce reviews rules in England.