CMA Rules on Fake Reviews: What the DMCC Act Means for Dental Practices

The DMCC Act 2024 made fake and misleading reviews a banned practice in the UK from 6 April 2025. The CMA can decide a breach and fine a business up to 10% of global turnover, without going to court. In March 2026 the CMA opened its first formal fake review investigations, including one into a firm alleged to have asked staff to write reviews. Asking staff, family or friends to review your practice is one of the clearest breaches. Treating negative reviews as private complaints, rather than publishing them, is also a risk under the Act.

The Digital Markets, Competition and Consumers Act 2024, known as the DMCC Act, is the UK law that makes fake and misleading consumer reviews an automatically unfair commercial practice. It is enforced by the Competition and Markets Authority, the CMA, which can now decide that a business has broken the law and impose a fine of up to 10% of global turnover without taking the case to court first.

In plain terms for a dental practice: you can no longer treat your Google reviews as something to quietly manage. The way you collect, display and respond to reviews is now covered by consumer law, and a regulator is actively enforcing it.

For a UK dental practice, the DMCC Act is the reason review compliance stopped being a theoretical concern in 2025 and became a real one in 2026.

Why this matters now, not in principle

The rules banning fake and misleading reviews came into force on 6 April 2025. For the first three months the CMA said it would help businesses comply rather than punish them. That grace period ended in July 2025, the CMA swept more than 100 review platforms, and in March 2026 it opened its first formal investigations into fake and misleading reviews under the Act.

The businesses named are large: Autotrader, Feefo, Dignity, Just Eat and Pasta Evangelists. A dental practice is not the CMA’s target. Two of those cases, though, describe conduct that dental practices carry out without thinking of it as breaking the law.

• Dignity, a funeral services provider, is being investigated over whether it asked its own staff to write positive reviews of its services. Asking staff to review the practice is one of the most common review mistakes in dentistry.
• The Autotrader and Feefo case concerns whether negative one star reviews were held back and left out of the star rating. Treating a bad review as a private complaint to be resolved quietly, rather than a review to be published, is the same underlying issue.

No findings have been made in any of these cases, and being investigated is not the same as being guilty. What the cases show is what the CMA considers worth acting on, and that is the useful signal for a practice owner.

What the DMCC Act bans

The DMCC Act treats several review practices as automatically unfair, which means they are considered a breach in themselves. The CMA does not have to prove that any patient was actually misled. The practice being carried out is enough.

The banned practices most relevant to a dental practice are:

• Submitting or commissioning fake reviews. This includes writing your own reviews, and asking staff, family, friends or suppliers to post them. A review must come from a genuine patient with genuine experience.
• Concealed incentivised reviews. Offering anything of value for a review, a discount, a free treatment, a prize draw entry, without clearly disclosing that the review was incentivised. In practice, disclosure inside a review is very hard to do properly, so the safe position for a dental practice is to offer no incentive at all.
• Misleading presentation of reviews or ratings. Displaying a star rating or a selection of reviews in a way that gives a false impression of overall patient experience. Hiding or suppressing negative reviews falls under this.
• Failing to take reasonable steps to prevent fake reviews. The Act places a positive duty on businesses that publish reviews, not just a duty to avoid dishonesty. If your website shows patient reviews, you are expected to take reasonable and proportionate steps to keep fake or misleading ones off it.

One point is worth repeating, because it changes how carefully a practice needs to think. These rules are strict liability. That means good intentions are not a defence. A practice that asked a few loyal patients’ family members to leave a kind word, meaning no harm at all, has still carried out a banned practice.

What a dental practice actually needs to change

Most practices are not doing anything they would recognise as cheating. The real risks are smaller and more ordinary, and they usually come from habits that once seemed harmless. Here are the four that matter most.

Stop asking staff to review the practice

This is the Dignity issue in miniature. A practice manager asks the nursing team to leave a Google review to help the new profile along. Every review is warm and genuine in sentiment, and every one is a fake review under the Act, because the reviewers are not patients giving an independent account. The same applies to the principal’s family, and to a friendly supplier.

Stop treating negative reviews as complaints to be buried

A dissatisfied patient posts a one star review. The instinct is to get it taken down or resolved privately so it disappears. Genuine negative reviews are not something a practice is entitled to remove, and a pattern of suppressing them is exactly what the Autotrader and Feefo case is about. Respond to the review, address the concern through your complaints process, and let the review stand. For how to respond without breaching confidentiality, see our guide to Google review policies for dentists.

Stop offering anything for a review

No entry into a prize draw, no discount on the next visit, no free whitening. This is the Pasta Evangelists issue. Even framed as a thank you, an undisclosed incentive for a review is a banned practice.

Stop filtering who gets asked

Sending review requests only to patients you expect to be happy produces a misleading rating, which is the presentation issue at the heart of several CMA cases. This is review gating, and it breaches Google policy as well as raising a DMCC concern.

The compliant alternative to all four is the same one described in our guide to asking patients for Google reviews: ask every patient, the same way, with no incentive and no script.

The duty to prevent, not just to avoid

The part of the DMCC Act that catches careful practices by surprise is the positive obligation. It is not enough to avoid posting fake reviews yourself. If your practice publishes reviews, for example by displaying Google reviews or a star rating on your website, you are expected to take reasonable and proportionate steps to prevent fake or misleading reviews appearing there.

For a small dental practice, reasonable and proportionate is not a heavy burden. It means being able to answer three questions:

1. Where do the reviews on your website come from? A live feed from Google is easier to defend than a hand picked selection typed onto the page, because a curated selection invites the question of what was left out.
2. How would you spot a fake or malicious review? You do not need a monitoring system, but you should be checking your profile regularly enough to notice a suspicious pattern.
3. What do you do when you find one? Report genuine policy breaches to Google, and do not simply delete honest criticism.

A practice that can answer those three questions has taken reasonable steps. A practice that displays a curated wall of five star reviews and has never thought about where they came from has not.

What actually happens if a practice breaches the rules

The headline penalty under the DMCC Act is a fine of up to 10% of global turnover. That figure is real, but for a single dental practice it is not the likely outcome, and it helps to be honest about the realistic risk rather than the scary maximum.

The CMA has finite resources and is focusing its formal investigations on large businesses whose conduct affects many consumers. A single practice is far more likely to encounter the consequences through other routes:

• Google removing the reviews, which happens automatically and at scale, and costs a practice its review history rather than a fine.
• A competitor or a disgruntled former employee reporting the practice to the CMA or to Google, which turns a low risk into an active one.
• A patient noticing that the practice’s rating does not match their experience, which is a reputational cost that no enforcement action is needed to trigger.

The proportionate way to read the DMCC Act is not as a likely fine. It is as confirmation that the informal norms around reviews have become law, that the regulator is now willing to act, and that the cheap, once common shortcuts now carry a downside that did not exist a few years ago.

A DMCC compliance checklist for dental practices

Seven checks. A practice that passes all seven is aligned with the DMCC Act as it is being enforced in 2026.

• No reviews from staff, family, friends or suppliers. Only genuine patients.
• No incentives for reviews, disclosed or otherwise. The safe position is none.
• No suppression of genuine negative reviews. Respond, do not bury.
• No sentiment filtering before a review request.
• Reviews on your website come from a defensible source, ideally a live feed rather than a hand picked list.
• Your profile is checked often enough to notice a suspicious pattern.
• You can describe your whole review process in a sentence without discomfort.

Summary

The DMCC Act 2024 turned fake and misleading reviews from a grey area into a banned practice, enforced by a regulator that can now issue its own fines. In March 2026 the CMA opened its first formal cases, and two of them describe conduct, staff written reviews and the suppression of negative reviews, that dental practices carry out routinely. The realistic risk for a single practice is not a CMA fine but the loss of its review history and the trust of its patients. The response is the same in every case: only genuine patients review, nobody is paid, no honest review is buried, and every patient is asked the same way.

Sources

• Digital Markets, Competition and Consumers Act 2024, Schedule 20; in force 6 April 2025 via SI 2025/272
• Competition and Markets Authority, Fake and misleading reviews: 5 businesses under CMA investigation, March 2026
• Competition and Markets Authority, Fake reviews guidance (CMA208)
• Competition and Markets Authority, Unfair commercial practices guidance (CMA207)