CMA Publishes Compliance Principles for Social Media Platforms on Reviews and Endorsements

On 28 August 2025, the Competition and Markets Authority (CMA) published updated guidance for social media platforms on reviews and endorsements. The CMA originally published the guidance and principles on 3 November 2022 and outlined that social media platforms have responsibilities under consumer protection law to prevent and tackle unlawful practices, including fake reviews and hidden advertising. 

This latest update sets out six revised key principles aimed at helping social media platforms comply with consumer protection law. The principles have now been aligned to reflect the Digital Markets, Competition and Consumers Act 2024 (DMCC), whereas the previous 2022 guidance related to the Consumer Protection from Unfair Trading Regulations 2008.

What does the updated guidance say?

As under the previous guidance, the CMA summarises that social media platforms have a duty to take reasonable and proportionate steps ensure that consumers are not misled by content that appears to be genuine user-generated material but is in fact commercial in nature. This includes consumer reviews which are fake/false, or which fail to disclose that they have been incentivised, or are misleading. Equally, in addition to the duties to act with professional diligence under the DMCC, platforms should take appropriate steps to remove such content from publication.

The CMA expects platforms to take a risk-based approach. This means conducting a risk assessment on the likelihood and impact of such material appearing on their platform, and implementing clear policies to prevent and remove banned reviews which is appropriate to the risks. 

The updated guidance should be considered alongside the CMA’s other guidance on reviews and social media endorsements, for example its detailed guidance on fake reviews (CMA208) and for platforms, influencers and brands: Unfair commercial practices: CMA207 - GOV.UK.

The six updated principles

According to the CMA, the following principles represent what practical steps it considers platforms should be taking to comply with consumer protection law:

Principle 1: Clear labelling of incentivised endorsements – Platforms should ensure that these are clearly identified as advertising and are clearly distinguishable from other content, and that fake reviews are not allowed.

Principle 2: Effective tools for labelling content – Platforms should provide content creators with tools so they are easily and effectively able to label any content as advertising.

Principle 3: Using available technology – Platforms should take appropriate, proportionate, proactive steps and use available technology to prevent hidden advertising and fake reviews from appearing on their sites.

Principle 4: Reporting systems – Platforms should make it simple for users to report suspected hidden advertising and fake reviews easily and effectively

Principle 5: Facilitate legal compliance by brands – Platforms should take proactive steps to inform brands of their terms of service, policies and any other information on incentivised endorsements and fake reviews.

Principle 6: Enforcement – Platforms should enforce their terms and conditions and take appropriate action when violations occur.

Key takeaways

Social media platforms should ensure that they keep compliance with consumer protection law under review, especially as practices and technologies continue to develop. While the principles are not legally binding in themselves, they reflect the CMA’s interpretation of what compliance with the DMCC looks like in practice. The CMA has the power to issue fines and directions to those in breach and although it recognises that each platform is different, taking account of the above principles can assist platforms in avoiding such breaches. The principles are not restrictive though and the CMA states that platforms may develop other ways of complying beyond what it has specified in the guidance.

If you have any questions or would otherwise like to discuss any of the issues raised in this article, please contact Richard Hugo, Amanda Leiu, or another member of our Commercial & Technology team.

This article was written by Fraser Campbell and Amanda Leiu.