Competition & Markets Authority
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CMA takes enforcement action against fake online reviews

A marketing firm has ceased writing fake online reviews for small businesses and will take steps to remove those already posted, following action by the CMA.

The Competition and Markets Authority’s (CMA) investigation into Total SEO & Marketing Ltd (Total SEO), a search engine optimisation (SEO) and online marketing company, found that between 2014 and 2015 it had written over 800 fake positive reviews for 86 small businesses that were published across 26 different websites which contain customer reviews.

Total SEO has co-operated with the CMA’s consumer law investigation. The company, and its directors, have undertaken to the CMA that they:

  • have ceased the practice of writing fake reviews for their clients; and
  • will take steps to remove the fake reviews already posted online.

In addition to this action, the CMA has written to Total SEO’s clients to warn them that third parties writing fake reviews on their behalf might lead to them breaking the law themselves. The small businesses concerned include car dealers, mechanics, landscape gardeners and other tradespeople.

The CMA has also produced a written brief explanation for businesses summarising how to comply with consumer protection law in relation to online reviews. In particular:

  • PR, marketing and SEO companies should not write or arrange fake reviews on behalf of their clients; and
  • businesses should not commission third parties to write fake reviews about them.

This follows the announcement last month that, in a separate case, 2 websites for finding tradespeople and a further 3 care home review sites have agreed to improve their practices for checking and presenting online reviews, in response to concerns raised by the CMA.

Nisha Arora, CMA Senior Director, Consumer, said:

With more than half of people in the UK using online reviews to help them choose what to buy, they are becoming an increasingly valuable source of information. Fake reviews can lead to people making the wrong decisions and fair-playing businesses losing out.

Search engine optimisation companies, PR and marketing agencies provide a valuable service to businesses, but they must do this lawfully. Our enforcement action against Total SEO makes clear that posting fake reviews about clients is unacceptable.

This is our latest action to ensure that consumers can trust in the opinions that they read on online, following the CMA’s report last summer into online reviews and endorsements. In the next few weeks, we expect to announce the outcome of our investigation into unlabelled endorsements.

Notes for editors

  1. The CMA is the UK’s primary competition and consumer authority. It is an independent non-ministerial government department with responsibility for carrying out investigations into mergers, markets and the regulated industries and enforcing competition and consumer law. For more information the CMA see our homepage or follow us on Twitter @CMAgovuk, Flickr and LinkedIn.
  2. The CMA’s investigation and subsequent action in this case did not relate to the practices of any of the websites on which the reviews appeared. The CMA has taken steps to notify as many of the websites as possible that reviews were posted on their site.
  3. Search engine optimisation usually forms part of a business’ online marketing strategy and involves increasing a website’s visibility in search engines so that it appears higher in search results.
  4. The CMA has produced three 60-second summaries for businesses on how to comply with consumer protection law on online reviews and endorsements.
  5. On 11 February, after engaging constructively with the CMA, Checkatrade, Trustatrader,, Care Opinion and Most Recommended Care all agreed to improve their practices. This was unrelated to the investigation into Total SEO.
  6. As part of its call for information the CMA produced an infographic (JPEG, 193KB) on consumer spending after reading online reviews.
  7. The Consumer Protection from Unfair Trading Regulations 2008 (CPRs) contain a general prohibition on unfair commercial practices, in particular misleading and aggressive practices. They also contain 31 banned practices which are prohibited in all circumstances. It is a banned practice to falsely claim or create the impression that a trader is not acting for purposes relating to his trade, business or profession, or to falsely represent oneself as a consumer.
  8. The CPRs are enforceable through the civil and criminal courts. Only a court can conclude whether a particular practice infringes the law.
  9. Enquiries should be directed to Siobhan Allen (, 020 3738 6460) or Simon Belgard (, 020 3738 6472).


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