Building trust through transparency: How the DMCC Act affects your dealership
The Digital Markets, Competition and Consumers Act 2024 (DMCC Act), effective since April 2025, introduced new legal obligations to prevent, detect and remove fake and misleading customer reviews.
What the DMCC Act means for dealerships
The DMCC Act bans fake reviews, hidden incentivised reviews and the misleading presentation of reviews. Dealerships, review providers (including Feefo and any other review providers that you work with) and publishers such as Autotrader are all responsible for ensuring they adhere to the legislation and failure to comply could, in the worst case, result in fines of up to 10% of global annual turnover or £300,000.
By complying now, you’re protecting your business from potential regulatory action and building customer trust.
Examples of the banned practices include, but are not limited to:
Obtaining fake reviews from people who haven't purchased vehicles from your dealership
Using hidden incentives to obtain reviews, where reviewers receive payments, discounts, or other benefits in return for a review, without clear disclosure
Only requesting reviews from customers who you know have had a positive experience (“cherry picking”)
Misleading presentation of reviews, such as suppressing negative feedback or manipulating review displays so that only positive reviews are prominent
Contacting customers to change a negative review
What the DMCC Act means for Autotrader
As the publisher of reviews, Autotrader now has an obligation to take reasonable and proportionate steps to prevent and remove fake and misleading reviews being published to our platform.
We have agreements in place with several review providers to share reviews and these have been reviewed following the DMCC Act. We are also putting in place new processes to monitor, investigate and take sanctions against retailers who are in breach of the DMCC regulations, which would also be a breach of our Dealer Reviews Business Rules.
Any customers found breaching these rules risk being removed from the Autotrader platform, either temporarily or permanently.
More information about our Dealer Reviews Business Rules can be found in our terms and conditions, available to view here
What should I do next as a dealership?
Working with an established review provider that will work with you to ensure you are complying with the DMCC regulations can help you to remain compliant. These platforms typically handle:
Customer verification processes
Review authenticity checks
Proper disclosure labelling
Ongoing monitoring and moderation
Technical compliance with DMCC requirements
All dealerships should review and, if necessary, amend their current review practices to ensure that they are compliant with the new legislation. These may include, but are not limited to:
Ensuring reviewers are genuine customers who have purchased vehicles
Maintaining records of all review-related activities
Taking "reasonable and proportionate steps" to prevent, detect, and remove fake and misleading reviews
Clear labelling of review sources and any incentives provided
Ensuring your team understands what constitutes compliance vs. violations
Reviewing your processes to ensure ongoing compliance
FAQs
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No. The DMCC Act doesn't mandate specific platforms. You can:
Choose from multiple established review providers, but you are responsible for ensuring the review provider is meeting its obligations under the DMCC
Use multiple platforms simultaneously
Develop your own compliant internal system
Mix approaches (e.g., use a platform for online reviews while managing customer testimonials internally)
The key is ensuring whichever approach you choose meets the DMCC Act’s requirements.
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The DMCC Act protects the value of your positive reviews by ensuring they're genuine. Reviews must reflect authentic customer experiences, which means:
Your positive reviews carry more weight with consumers
Negative reviews provide valuable feedback for improvement
Overall, genuine mixed reviews are more trusted than suspiciously perfect ratings
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Non-compliance can potentially result in fines up to 10% of global annual turnover or £300,000, with individuals facing fines up to £150,000. However, the focus is on encouraging compliance rather than punishment. The CMA typically works with businesses to achieve compliance before taking enforcement action.
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Retailers are not allowed to submit reviews that have been incentivised to the Autotrader site.
An incentivised review is a review that has been written in exchange for a benefit given to the reviewer. This could include money, a discount, a voucher, freebie, an invitation to an event, more favourable terms than those offered to the general public, or any other benefit. It also includes a situation where the reviewer has a financial interest in the retailer or the product being reviewed (e.g. if they are an employee of the retailer) or have a commercial link with the retailer (e.g. if they are a supplier of the retailer).
The DMCC Act bans incentivised reviews, unless the fact that the review has been incentivised is clearly apparent either in the wording of the review itself or by some other means (e.g. the labelling of the review).
Autotrader (like many other review platforms that we work with) cannot ensure that incentivised reviews are labelled on the site, which means that, if we were to publish incentivised reviews, it would likely be misleading and in breach of the DMCC Act. Therefore, we do not allow retailers to submit incentivised reviews in any case.
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According to the CMA’s guidance on the DMCC Act, entry into a prize draw in return for a review is unlikely to be an incentivised review for the purposes of the DMCC Act. This is on the basis that the reviewer is being offered a chance to win, but not guaranteed a direct benefit, in return for their review.
Some traders and review companies offer to make a charitable donation or plant a tree in return for a review. This is not specifically mentioned in the CMA’s guidance, but arguably there is no direct benefit to the reviewer, as the benefit is to the charity or society in general.
Some retailers send customers a gift on completion of a sale. Again, this is not specifically mentioned in the CMA’s guidance, but may be acceptable in some circumstances (e.g. provided that the gift is sent to all customers regardless of whether they have had a good or bad experience and provided that it is not specifically tied to a request for a review).
The above examples are subject to interpretation of the law and may depend on the circumstances. Autotrader cannot provide legal advice and therefore retailers are advised to take their own legal advice before offering any incentives to ensure that they are fully complaint with the law.
The DMCC Act isn't a burden, it's an opportunity for retailers to stand out in an increasingly competitive market and ensure they are adhering to best practice.
Genuine reviews from real customers who've purchased a vehicle are far more valuable than any artificial testimonials. The DMCC Act ensures that this authentic feedback gets the recognition it deserves, helping honest retailers stand out from the competition.