WAJD Learning

Module 2 of 2 · 45 minutes

Reviews, outreach and chatbots

By the end of this module you will be able to

  • State the law on fake and incentivised reviews
  • Explain the business's duty to prevent fake reviews
  • Apply the consent rules to electronic marketing
  • Say what a customer must be told about a chatbot
  • Keep personal data out of unapproved tools

Work through it

1 interactive for this module, built on the WAJD Teach engine. Nothing moves until you ask it to, and every one has a written version if you would rather read it.

Watch: Emma and George talk it through

3 minutes. Captions are on, and the same conversation is written out in full below. The voices are computer generated.

Emma George, a supplier offered to generate fifty five star reviews for our new product. Tempting. Legal?

George No. Since 6 April 2025, under the Digital Markets, Competition and Consumers Act, it's a banned practice to submit or commission fake consumer reviews. In all circumstances.

Emma What counts as fake?

George A review written by a tool for a customer who doesn't exist, or who never said it. And a real review rewritten to be more favourable than what the customer wrote.

Emma What about incentives? We give a discount for a review.

George Allowed, but it must be clearly identified as incentivised. And you can't publish reviews in a misleading way.

Emma Meaning?

George Hiding the bad ones. Or an AI summary of your reviews that leaves them out. That presents review information in a misleading way.

Emma And the penalty?

George The Competition and Markets Authority can now decide for itself that consumer law's been broken, and fine a business up to ten per cent of its global annual turnover. Without going to court.

Emma That's serious. Is not writing them enough?

George No. If you publish reviews, you're expected to take reasonable and proportionate steps to prevent fake ones and remove them when found. A policy. A way to check a reviewer was a customer. A way to report a suspect review.

Emma Different subject. I've got a tool that writes a personalised email to every lead on a list I bought.

George AI can write the message. It can't give you permission to send it. Email and text marketing to individuals needs their consent, with a narrow exception for your own existing customers.

Emma But it's personalised.

George Which makes it worse, not better. Personalisation uses personal data. And a bought list personalised by a tool is still an unlawful campaign.

Emma Who enforces that?

George The Information Commissioner's Office. And the Data (Use and Access) Act 2025 raised the maximum fines to the same level as data protection law.

Emma Last one. Our website chatbot has a name and a photo. People think it's a person.

George Then fix that. Presenting an automated system as a human being is misleading. And if you serve customers in the EU, the AI Act has required since 2 August 2026 that people are told they're dealing with an AI system.

Emma And if it gets a refund policy wrong?

George Then you told the customer that. A chatbot speaks for the business. Test what it says, keep a record, and give people an easy route to a human being.

The written material

Fake reviews are banned

The Digital Markets, Competition and Consumers Act 2024 brought new consumer protection rules into force on 6 April 2025. They ban, in all circumstances, submitting or commissioning fake consumer reviews, and publishing reviews or review information in a misleading way. Incentivised reviews must be clearly identified as such.

A review written by a tool, for a customer who does not exist or who never said it, is a fake review. So is a real review rewritten by a tool to be more favourable than what the customer wrote. Summaries count too: an AI generated summary of your reviews that leaves out the bad ones presents them in a misleading way.

You must also take steps to stop them

The rules do not only forbid writing fake reviews. A business that publishes reviews is expected to take reasonable and proportionate steps to prevent fake ones appearing and to remove them when found. The Competition and Markets Authority has published guidance on what that means, and after the rules came in it reviewed a large number of websites and wrote to dozens of businesses about their practices.

For a small business that means a policy, a way of checking that a reviewer was a customer, a way for people to report a suspect review, and not hiding the reviews you do not like.

AI can write the message. It cannot give you permission to send it

The Privacy and Electronic Communications Regulations govern marketing by email, text and automated call. Marketing to individuals by email or text needs their consent, with a narrow exception for your own existing customers who were given the chance to opt out. Every message must identify the sender and offer a way to stop.

AI makes it trivially cheap to write a thousand personalised messages, which makes the rules matter more, not less. The Information Commissioner's Office enforces them, and the Data (Use and Access) Act 2025 raised the maximum fines to the same level as data protection law. A list scraped or bought, then personalised by a tool, is still an unlawful campaign.

Chatbots and customers

If a customer is dealing with a chatbot, do not let them think it is a person. Presenting an automated system as a human being is a misleading practice under consumer law, and if you serve customers in the European Union, the EU AI Act has required since 2 August 2026 that people are told when they are interacting with an AI system unless it is obvious.

A chatbot also speaks for the business. If it tells a customer something untrue about a price, a refund or a product, the customer was told that by you. Test what it says, keep a record, and give people an easy route to a human being.

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