Dental reviews rules in the UK: the DMCC Act, the ASA and Google's policy
Last reviewed against the regulators’ own text, linked in the sources below.
This is general information, not legal advice.
On this page
Since 6 April 2025, fake reviews and hidden incentives for reviews have been banned outright in UK consumer law, under the Digital Markets, Competition and Consumers Act 2024 (the DMCC Act).1 For a dental practice, that sits alongside two older rulebooks: the ASA's rules on testimonials in ads, and Google's own review policy, which is stricter than the law on incentives.
The three sit side by side below, and only the rules are covered. How to get more reviews within them is covered in getting more Google reviews within policy, and the wider picture is on the dental advertising rules hub. This is general information, not legal advice.
- Law (DMCC Act): no fake reviews, no concealed incentives, no misleading selection of reviews.
- ASA (CAP Code): testimonials in ads must be genuine, held on file, used with permission and not misleading.
- Google: no incentives of any kind, no selective asking, no reviews from anyone with a conflict of interest.
The law on fake and incentivised reviews
The ban is in paragraph 13 of Schedule 20 to the DMCC Act. I read it through the Competition and Markets Authority's guidance on that paragraph, CMA208, which quotes and footnotes each sub-paragraph.2 The CMA (Competition and Markets Authority) is the UK regulator that enforces consumer law alongside Trading Standards.
Three things are banned:
| Banned practice | What the CMA says it means | Dental example |
|---|---|---|
| Fake review | A review that "purports to be, but is not, based on a person's genuine experience"2 | Staff or family posting five-star reviews as patients |
| Concealed incentivised review | A review someone was commissioned to write, where that fact "is not made apparent"2 | A free hygiene visit for a review, with no label on the review |
| Misleading publication | Suppressing genuine negative reviews or promoting positive ones selectively2 | Showing only five-star reviews on the website under "What our patients say" |
Two details matter more for practices than the headline ban.
Staff count. The CMA's examples of commissioning include "a trader requesting a member of staff to write a review".2 A dental nurse leaving a review of the practice they work at is a problem under the law and under Google's conflict-of-interest rule below.
Incentives are not banned outright in law, but they must be declared. CMA208 says traders may incentivise reviews if they tell consumers the review was incentivised and it still reflects a genuine experience.2 In practice that route is closed for Google reviews, because Google bans incentives entirely.
Penalties can reach £300,000 or 10% of turnover, whichever is higher.3
Testimonials in ads
A testimonial is a patient's statement about their experience used in marketing: on the website, in an ad, in a leaflet. The ASA (Advertising Standards Authority) enforces the CAP Code, the rulebook for non-broadcast ads, and its section 3 sets the rules.
| CAP rule | Requirement4 |
|---|---|
| 3.45 | Make clear where consumer reviews have been incentivised |
| 3.46 | Do not publish reviews in a misleading way, including hiding negatives or giving positives more prominence |
| 3.47 | Hold documentary evidence the testimonial is genuine, and hold contact details for the person |
| 3.48 | The testimonial must relate to the advertised product |
| 3.49 | Factual claims inside a testimonial must not mislead |
| 3.50 | No testimonial without permission |
For dentistry, the ASA treats before-and-after photos as testimonials. Its 2024 guidance says practices need "documentary evidence that the images are genuine", permission, and contact details for the person.5 Results shown must be representative of what most patients would get.
Rule 3.49 catches a common mistake: a patient review that says "painless" or "permanent" is still a claim when you put it in your ad, and you need evidence for it. The broader rules on claims are on the page about what the ASA looks for in dental ads.
Google's review policy
Google's Maps user-generated content policy applies to every review on a Google Business Profile. It's stricter than the law in two places.6
- No incentives at all. Businesses must not "offer incentives" for any review, "such as payment, discounts, free goods and/or services".6 A declared incentive, which the DMCC Act allows, still breaks Google's policy.
- Conflict of interest. Reviews based on a conflict of interest are not allowed, including "current or former employment".6
Google also says merchants "should not require or pressure users" to leave reviews while on the premises.6 Asking at the desk is fine. Standing over a patient with a tablet isn't.
Google's stated consequences run from removing the content to "suspending the account privileges to account termination".6
| Question | DMCC Act | ASA (in ads) | |
|---|---|---|---|
| Can I offer an incentive for a review? | Only if declared on the review2 | Must be made clear4 | No6 |
| Can staff review the practice? | No, if presented as a patient review2 | Not as a patient testimonial | No6 |
| Can I only ask happy patients? | Risky: may be misleading2 | Rule 3.46 applies to what you show | No6 |
| Can I hide negative reviews? | No2 | No4 | Not your call: Google hosts them |
Review gating
Review gating means filtering patients before they are asked for a public review: a survey or "How did we do?" message, then only the happy ones get sent the Google link, while unhappy ones go to a private feedback form.
All three rulebooks treat this as a problem.
- Google names it directly: businesses must not "selectively solicit positive reviews from customers".6
- CMA208 says cherry-picking may be done "by encouraging just those who are satisfied to leave reviews".2
- CAP rule 3.46 covers giving greater prominence to positive reviews in marketing.4
A private feedback survey is fine on its own. It becomes gating when its answer decides who gets the public review link. The clean version: every patient gets the same request, at the same point in their treatment, with the same link. The CMA confirms that "merely emailing customers generally to ask if they wish to provide a review" isn't prohibited.2
How to ask for reviews and reply to them inside these rules is set out in getting and answering Google reviews. For a free first look at your review requests and replies, email Fayez@imfayez.com.
Sources
-
Competition and Markets Authority, "Consumer protection: enforcement guidance (CMA58)", 4 April 2025, footnote 3: consumer protection provisions of the DMCC Act enter into force on 6 April 2025. https://assets.publishing.service.gov.uk/media/67ef946c199d1cd55b48c7ba/Consumer_protection_enforcement_guidance.pdf (accessed 1 October 2026). ↩
-
Competition and Markets Authority, "Fake reviews (CMA208): guidance on the prohibition under paragraph 13 of Schedule 20 to the DMCC Act 2024", 4 April 2025, paragraphs 2.5, 2.9, 2.10, 3.6, 3.7, 4.3 to 4.5 and chapter 3 examples. https://assets.publishing.service.gov.uk/media/67eeb64fe9c76fa33048c790/CMA208_-_Fake_reviews_guidance.pdf (accessed 1 October 2026). The statute text on legislation.gov.uk could not be loaded on the access date; the paragraph references are taken from the CMA's footnotes. ↩ ↩2 ↩3 ↩4 ↩5 ↩6 ↩7 ↩8 ↩9 ↩10 ↩11 ↩12 ↩13
-
Competition and Markets Authority, CMA58, paragraphs 5.4 and 5.22. https://assets.publishing.service.gov.uk/media/67ef946c199d1cd55b48c7ba/Consumer_protection_enforcement_guidance.pdf (accessed 1 October 2026). ↩
-
Committee of Advertising Practice, UK Code of Non-broadcast Advertising (CAP Code), section 3, rules 3.45 to 3.50. https://www.asa.org.uk/type/non_broadcast/code_section/03.html (accessed 1 October 2026). ↩ ↩2 ↩3 ↩4
-
Advertising Standards Authority, "This is not a drill: dental ads wisdom", 9 May 2024. https://www.asa.org.uk/news/this-is-not-a-drill-dental-ads-wisdom.html (accessed 1 October 2026). ↩
-
Google, "Prohibited and restricted content", Maps user-generated content policy (fake engagement and conflict of interest sections). https://support.google.com/contributionpolicy/answer/7400114 (accessed 1 October 2026). ↩ ↩2 ↩3 ↩4 ↩5 ↩6 ↩7 ↩8 ↩9