Fake Reviews and Drip Pricing: What the DMCC Act Means for Agency Websites

Reviews and prices are two of the first things a visitor looks at on an agency website. Both are now covered by specific rules under the Digital Markets, Competition and Consumers Act 2024. This guide explains the rules in plain terms and turns them into practical steps for your site. It is a summary, not legal advice.

The law in brief

The consumer protection provisions of the Digital Markets, Competition and Consumers Act 2024 apply to commercial practices from 6 April 2025 onwards.^[1] They replaced the Consumer Protection from Unfair Trading Regulations 2008. Two parts matter most to agency websites. Fake consumer reviews were added to the list of banned practices that are always unfair, whatever their effect. Drip pricing sits under a different heading: it is prohibited as a misleading omission, through the rules on what an invitation to purchase must show.

Enforcement changed too. The Competition and Markets Authority gained the power to impose fines of up to 10% of global turnover for breaches of consumer protection law, without first going to court.^[2] Trading Standards continues to enforce consumer law as well.

Fake reviews

The full text of the banned practice is in paragraph 13 of Schedule 20 to the Act. The CMA's guidance summarises what it prohibits as submitting or commissioning fake reviews, publishing reviews in a misleading way, and failing to take reasonable steps to prevent and remove fake or misleading reviews.^[1] As CMS put it before the rules began, consumer reviews that are not based on a person's genuine experience but appear to be will be prohibited.^[2]

What this means on your website

A simple review policy

Propertymark advised its members to publish fake-review prevention policies after the Act came into force.^[3] A useful policy for an agency site fits on one short page and answers four questions:

1. Where do reviews come from? For example, a named independent review platform, or invitations sent to clients after completion.
2. Who can leave one? Clients who have used your services, and nobody connected to the agency.
3. What do you moderate, and why? For example, removing personal data about third parties or abusive language, never removing a review because it is critical.
4. How do you show them? For example, all reviews in date order, with any incentive disclosed.

Link the policy from wherever reviews appear, including the home page widget and branch pages.

Review widgets

If your site embeds a widget from a review platform, check it before you rely on it. Find out how it chooses what to display. Some can be set to show only top-rated reviews, which may give a misleading impression. Others show an average score that might be based on a small or old sample. If the widget cannot be configured to give a fair picture, a plain link to your full profile on the platform is often better than a filtered carousel.

Drip pricing

Drip pricing is not on the banned practices list. It is caught by the rules on misleading omissions: under section 230 of the Act, an invitation to purchase must give the total price, including any mandatory fees, taxes and charges, and the CMA's guidance gives showing an initial headline price and then adding further mandatory charges as an example of what is prohibited.^[1] CMS gives booking fees, delivery charges and joining fees as examples of mandatory charges that must be included in the headline price.^[2]

Where agencies need to look

• Advertised sales fees. If you advertise a fee for selling a home, any compulsory extras, such as a mandatory marketing pack or an administration charge, belong in the figure people see first. Optional extras can be listed separately and clearly as optional.
• Landlord service prices. A tenant-find or management price should not grow compulsory add-ons, such as set-up fees, further down the page. If a fee always applies, include it.
• VAT. Consumer-facing prices should include VAT. The letting fee guidance makes the same point about fees including tax.^[4]
• Rental listings. Tenant fees are tightly restricted in England by the Tenant Fees Act 2019, so a rental listing should not suggest that extra compulsory payments will follow the stated rent and permitted payments.

Responding to critical reviews

The rules do not require you to keep quiet about reviews you think are unfair. They require you not to suppress genuine reviews or present a misleading picture. The better response to a critical review is usually a calm public reply that acknowledges the experience, explains briefly what you have done or will do, and offers to continue the conversation privately. Readers often judge an agency as much by how it responds to criticism as by the criticism itself. Where you suspect a review is not genuine, such as one written by a person who never used your agency, report it to the platform through its own process rather than removing it from your website display without explanation.

Building these rules into the website

Most of this comes down to how the site is built and maintained rather than one-off fixes. When we build a site, we set it up so that:

• prices for agency services are entered once, including VAT and any compulsory elements, and reused on every page where they appear, so the figures never disagree;
• optional extras are shown in a separate, clearly labelled list;
• review displays are set up to show a fair picture, with a link to the review policy beside them;
• testimonials are only used with a record of the client's permission;
• team pages never carry quotes about individual staff unless they come from genuine clients.

What happened in the first months

When the rules began, the CMA said that for the new banned practice on fake reviews it would spend the first three months helping businesses comply before taking enforcement action.^[5] That period has long passed. The safest assumption is that review and pricing practices on agency websites are now in scope for enforcement like any other business.