How London ecommerce teams run review software under CMA scrutiny

What to take away

Why London ecommerce teams face the closest CMA, ASA and ICO scrutiny

London is the UK's largest ecommerce market, and all three review regulators sit within it. The Competition and Markets Authority is the UK's competition and consumer enforcement authority, and it has taken action against businesses that misrepresent reviews. In 2016 the CMA secured undertakings from Total SEO & Marketing Ltd after it posted fake online reviews.

The Advertising Standards Authority regulates advertising claims, including ratings and testimonials. The Information Commissioner's Office enforces data protection law, and its enforcement action covers unlawful marketing and review data use. The ASA's 2019 ruling on TripAdvisor examined claims that reviews could be trusted.

Being headquartered in the same city as your regulator changes the calculation. A London team cannot treat compliance as a distant risk. The CMA can fine up to 10 per cent of global turnover under the Digital Markets, Competition and Consumers Act 2024, whose consumer protection provisions commenced on 6 April 2025.

The ASA can order an ad to be withdrawn. The ICO can issue fines and enforcement notices for misuse of personal data in review collection.

Proximity also means visibility. National media and trade press are based in London, so a CMA investigation into a London retailer gets covered quickly. That reputational risk is often the bigger concern for boards.

The Consumer Rights Act 2015 and UK GDPR set the floor. The CMA's guidance on online reviews adds specific expectations: do not suppress negative reviews, do not incentivise positive ones without disclosure, and do not present reviews as verified if they are not. London teams should treat these as operational requirements, not legal theory.

For a deeper look at how data protection law applies to review platforms, see our guide to commerce reviews data protection.

Marketplace seller rules London retailers must build into review software

Many London retailers sell on marketplaces as well as their own sites. Each marketplace has its own review rules, and the seller carries the risk.

Amazon's seller policies on customer reviews prohibit review manipulation, incentivised reviews and reviews written by family members. The Amazon seller policies also require sellers to report any suspected abuse. If a London seller uses review software that sends automated review requests, those requests must comply with Amazon's rules on buyer communications.

Other marketplaces, including eBay and Etsy, have similar restrictions. The common threads are: no conditional incentives, no review gating that only asks happy customers, and no editing of review content.

For London teams, this creates a design requirement. Your customer review software must be able to segment review requests by channel. A request sent to an Amazon buyer must follow Amazon's rules; a request sent to your own-site buyer can follow your own policy, within CMA and ASA limits.

An illustrative composite, not a named client: a London fashion retailer uses Trustpilot for its own site and a separate integration for Amazon. The software tags each request with the source channel. When Amazon updates its policy, the retailer updates one template, not the whole system.

That segmentation also helps with the CMA. If the CMA asks how you handle incentivised reviews, you can show that incentives are only offered on your own site, with clear disclosure, and never on marketplaces where they are banned.

The rules are not static. London teams should review marketplace policy updates monthly, because changes often arrive with little notice. Our commerce reviews UK rules and compliance guide covers the wider legal picture.

Agency availability and day rates across the London cluster

London has the UK's largest concentration of review agencies and independent moderators. That is an advantage and a cost.

Agencies in Shoreditch, Clerkenwell and Soho offer review management, moderation and compliance auditing. Typical London day rates, before VAT, are set by experience, sector and contract length.

The cluster also includes legal firms with advertising and consumer law practices. If you need a review of your review software controls before a CMA query, a London firm can turn it around quickly, at London rates.

Outside London, Manchester and Birmingham agencies charge roughly 20 to 30 per cent less for similar work. The difference reflects access to regulators and London media, not a different review law.

When selecting an agency, ask for evidence of CMA or ASA case experience. Ask how they handle a negative review that is factually wrong. Ask what they document. A good agency will have a template for enforcement queries. Our commerce reviews selection checklist sets out the questions to ask.

One caution: some London agencies promise to "manage" reviews in ways that edge into suppression. That is a CMA risk. Choose an agency that documents its moderation decisions and can show a consistent policy.

Review software controls large London retailers deploy

Large London retailers do not rely on platform defaults. They configure specific controls.

These controls are not just for compliance. They also improve review quality. A moderation queue with a clear policy reduces spam and fake reviews, which in turn makes the review section more useful to shoppers.

The controls need to be tested. A London team should run a quarterly check: submit a test review, see if it is moderated correctly, and confirm the system records it.

For marketplaces, the controls extend to seller onboarding. A London marketplace should check that new sellers understand the review rules and have a way to report abuse. Amazon's policy requires sellers to report suspected review abuse, and marketplaces often mirror that requirement.

Platforms used by London teams include Trustpilot, Feefo, Reviews.io, Yotpo and Bazaarvoice. The table compares typical use, not a ranking.

What London teams should document before an enforcement query

If the CMA, ASA or ICO asks about your reviews, you will need documents, not assurances. Build the file now.

A sample policy template should cover collection, moderation, incentives and removal, and name the person who owns each step.

An illustrative composite, not a named case: a London electronics retailer received a CMA query about incentivised reviews. Because it had a policy, an incentive register and audit logs, it responded within a week. The CMA closed the query without action. That file cost less than a day of legal time.

The same documentation helps with the ICO. If a customer complains about how their review data was used, you can show your retention schedule and consent records. The ICO's enforcement action often focuses on businesses that cannot show a lawful basis.

The ASA is less likely to ask for documents, but it will ask for substantiation of claims. If your site says "rated 4.8 by verified buyers", you need the data behind that claim. Keep it.

Finally, document your agency's role. If a London agency moderates reviews for you, the responsibility remains yours. The contract should say who owns the policy and who keeps the records.

Common questions