Rules and trust

Fake review rules: FTC and UK DMCC Act for beauty brands

By Hasan Ali, Founder & Growth Operator at Cliktron
Published 21 October 2026 · Updated 21 October 2026 · 6 min read

Key takeaways

  • US: the FTC’s rule on reviews and testimonials (16 CFR Part 465) has been in force since 21 October 2024.
  • UK: the DMCC Act made fake reviews a banned practice from 6 April 2025, with fines of up to 10% of global turnover.
  • EU: since 2022, traders must take reasonable steps to check reviews come from real customers.
  • Asking every customer for an honest review is fine. Paying or rewarding only good reviews is not.
  • Never change what a customer wrote. Fixing an obvious typo is a different thing from changing the meaning.

What does the FTC rule ban in the US?

The FTC’s Trade Regulation Rule on the Use of Consumer Reviews and Testimonials came into force on 21 October 2024. In short, it bans:

  • Fake reviews and testimonials, including ones written by AI or by people who never used the product.
  • Buying or selling reviews, and paying or rewarding people for reviews that must be positive (or negative about a competitor).
  • Insider reviews from staff or their families without clear disclosure.
  • Review suppression: using threats to stop bad reviews, or hiding negative reviews while implying you show them all.
  • Fake “independent” review sites that you secretly control.

The rule lets the FTC seek civil penalties for each violation, so this isn’t just a warning letter anymore.

What changed in the UK with the DMCC Act?

From 6 April 2025, the Digital Markets, Competition and Consumers Act added fake reviews to the list of practices that are always unfair. That covers submitting or commissioning fake reviews, hiding that a review was incentivised, and publishing reviews in a misleading way. The CMA can now fine businesses directly, up to 10% of global turnover, and it has said reviews are a focus. Its guidance (CMA208) explains what businesses must do.

What are the rules in the EU?

Since the Omnibus Directive applied in May 2022, it has been banned to claim reviews come from real customers without taking reasonable steps to check, and to submit or commission fake reviews. Many shops now only let verified buyers review, and explain how they check reviews.

The quick checklist

DoDon’t
Ask every customer for an honest reviewAsk only happy customers, or filter out unhappy ones
Show all reviews, good and badHide negative reviews while implying you show them all
Offer the same small thank-you for any review, if you offer one, and disclose itReward only positive reviews
Mark staff or gifted-product reviews clearlyLet staff or family post reviews as customers
Keep the customer’s own wordsRewrite reviews to say more than they said
Answer negative reviews politelyThreaten people over bad reviews
Let only verified buyers review, where you canCopy reviews from other sites or products

Can I edit customer reviews?

You can fix things that don’t change meaning, like removing personal data or offensive words, if your policy says you do. Don’t add words, make a review sound more positive, or move a review from one product to another. If a short review isn’t useful, the honest fix is to ask that customer for more detail.

How do I get more good reviews the honest way?

  • Ask at the right time: after the customer has used the product long enough to see results.
  • Make it easy: one click from the email to the review form, on mobile.
  • Ask useful questions: skin type, how long they used it, what changed. Detailed reviews help the next shopper and AI tools.
  • Reply to every negative review: a calm, helpful reply often wins more trust than a perfect score.
  • Ask past customers too: many happy customers never thought to leave a review.

How we’d approach this at Cliktron

  • Audit: check your review app settings, email requests and any incentives.
  • Fix: show all reviews, disclose incentives, and label staff or gifted reviews.
  • Grow: a review request flow timed to results, with questions about skin type and time used.
  • Use: put real reviews beside the product name and in ads, word for word.

Your next step

Your brandStart here
Indie ($10–30k a month)Check you show all reviews and that any incentive is offered for any review.
Rising ($30–150k)Add a timed review request flow and verified-buyer badges.
Leading ($150–500k)Write a review policy, train your team, and check creators’ disclosures in every market.

Common mistakes

  • Offering a discount only to customers who leave five stars.
  • Asking friends, staff or creators to post reviews without disclosure.
  • Hiding or deleting low ratings.
  • Rewriting short reviews to make them sound better.
  • Using reviews from one product on another.

Questions founders ask

Can I offer a discount for leaving a review?

Only if you offer it for any honest review, good or bad, and disclose it. Rewarding only positive reviews is banned.

Can I send free products to creators for reviews?

Yes, if their content clearly discloses the free product or payment, and you don’t tell them what to say about the results.

Do I have to show one-star reviews?

You can’t hide them while presenting the rest as all your reviews. You can remove reviews that break a clear, fair policy, like spam or abuse.

Does this apply to small brands?

Yes. The rules apply to businesses of any size selling to people in those markets.

Is this legal advice?

No. It’s a plain summary for founders. Check with a lawyer for your situation.

Sources

  1. FTC, Trade Regulation Rule on the Use of Consumer Reviews and Testimonials, 16 CFR Part 465, published 22 Aug 2024, in force 21 Oct 2024: ftc.gov
  2. UK Digital Markets, Competition and Consumers Act 2024, Schedule 20, in force 6 Apr 2025; CMA guidance on fake reviews (CMA208), 4 Apr 2025: gov.uk
  3. Directive (EU) 2019/2161 (Omnibus Directive), applied from 28 May 2022: eur-lex.europa.eu
  4. CMS, “No more faux five-stars: the DMCC Act bans fake reviews”: cms.law
Hasan Ali

About the author

Hasan Ali

Founder & Growth Operator at Cliktron, a growth team for skincare, beauty and personal care brands. Since 2020 he has served 138+ founders and completed 400+ projects.

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