The Digital Markets, Competition and Consumers Act 2024 came into force in April 2025, and the CMA wasted no time. By March 2026, Autotrader and Feefo were under formal investigation for suppressing negative reviews. But the law applies to every business that manages customer reviews — not just the platforms being investigated.
This article breaks down what the DMCCA actually requires from your review management tool, in plain English, so you can assess your own compliance without needing a lawyer in the room.
The Core Principle
The DMCCA's fake review provisions rest on one fundamental principle: consumers have the right to see genuine, unfiltered feedback from other customers. Any practice that distorts, suppresses, or manipulates the public picture of customer sentiment is illegal.
For dealer groups, this translates into a practical test: does your review management tool give every customer — regardless of their likely sentiment — an equal and equally prominent opportunity to leave a public review?
Five Specific Requirements
1. No sentiment routing
Your review tool cannot direct happy customers to Google while steering unhappy customers toward private feedback forms, internal surveys, or complaint channels. If the "sad face" path leads somewhere different from the "happy face" path — and that difference reduces the likelihood of a negative public review — you have a compliance problem.
The critical test is prominence. If a happy customer is one click from Google and an unhappy customer needs to navigate through a "contact us" form to find a public review link buried at the bottom, that is not equal prominence. The CMA has been explicit about this.
2. No review suppression
Every genuine customer review must be allowed to reach the public platform. Your tool cannot filter, delay, moderate, or prevent negative reviews from being published. If a customer writes a legitimate 1-star review and it does not appear publicly, that is suppression.
This does not mean you cannot respond to negative reviews or attempt to resolve issues — you absolutely should. But the resolution must happen alongside the public review, not instead of it.
3. No selective solicitation
You cannot only request reviews from customers you expect to leave positive feedback. The DMCCA requires that review solicitation is systematic and non-discriminatory. Every customer in the same transaction category should receive the same invitation, on the same timeline, through the same channel.
4. No follow-up chasing
Sending multiple follow-up messages to customers who haven't yet left a review — particularly after positive transactions — creates an asymmetric pressure that inflates positive review volume. Best practice under the DMCCA is one invitation per transaction, with no follow-up reminders.
5. Accurate aggregated ratings
If your platform publishes or contributes to aggregated star ratings, those ratings must include all genuine reviews. Excluding negative reviews from the calculation — as the CMA alleges Feefo did for Autotrader — produces a misleading rating that violates the Act.
How to Audit Your Current Tool
Walk through your own review process as if you were a dissatisfied customer. Click the unhappy option. Count the clicks to reach a public Google review page. Then do the same as a satisfied customer. If the journeys are not identical in length, prominence, and accessibility, your tool has a compliance gap.
Then ask your provider three questions:
- Can you provide documented legal sign-off confirming your platform's compliance with the DMCCA fake review provisions?
- Does your platform use any algorithm or mechanism to predict customer sentiment and route them accordingly?
- Are all genuine reviews — including 1-star reviews — passed through to public platforms without filtering?
If your provider cannot answer all three with documented evidence, you should be concerned.
What a Compliant Tool Looks Like
DOXA was architecturally designed to pass these tests. Every customer receives one message after their transaction. If they indicate satisfaction, they are directed to Google. If they indicate dissatisfaction, they are presented with two options of identical prominence: leave a public review, or contact the business privately. The customer chooses. There is no routing, no algorithm, no suppression.
Taylor Wessing LLP reviewed DOXA against the DMCCA in December 2025 and confirmed full compliance. We are happy to share a summary of that analysis with any dealer group that wants it.
What To Do Next
If you have not yet audited your review management process against the DMCCA, do it this week. The CMA's investigation of Autotrader and Feefo is not the end of enforcement — it is the beginning. The next round of investigations will focus on the businesses using these tools, not just the tool providers.
DOXA offers a free compliance audit for any UK dealer group. We will walk through your current process, identify any areas of exposure, and provide a clear recommendation — whether that involves DOXA or not.
Contact us: sales@doxa.co · +353 1 908 1570 · doxa.co/compliance