On 19 October 2026, the Italian Competition Authority (Autorità Garante della Concorrenza e del Mercato – AGCM) published its new Guidelines on online reviews. Although they are expressly aimed at the restaurant and tourism/hospitality sectors, the Guidelines also offer useful insights for businesses in other sectors that use reviews as a marketing and reputation tool. For such businesses, the document provides an opportunity to assess the compliance of their internal procedures and evaluate how they collect, manage and present reviews to consumers.
Transparency on how reviews are published, ranked and moderated
To give consumers clear and easily accessible information on how reviews are managed, the AGCM recommends making available the criteria used to publish, rank and moderate reviews, as well as the methods used to classify them as “verified” or “authentic”.
In particular, the Authority recommends that this information be available directly in the interface where the reviews are displayed, including through a clearly identified link.
Verifying the authenticity of reviews
In particular, businesses that give access to consumer reviews should adopt reasonable and proportionate measures to verify that reviews come from consumers who have actually purchased or used the product or service reviewed; such measures should take into account the nature of the activity and the economic size.
The AGCM identifies three categories of measures for carrying out these checks: - tools to verify that the consumer has actually used or purchased the product or service, such as requesting genuine tax or accounting documentation proving the purchase or use, including debit or credit card statements;
- tools to make the author of a review traceable, such as systems for registering review authors on the business's own channel, confirmation links sent to the reviewer's email address, or IP address checks;
- automated tools to detect fraudulent activity by identifying warning signs, such as many reviews posted in a short period from the same IP address, or repetitive language patterns.
The measures adopted should, however, be tailored so as not to unduly hinder the publication of genuine reviews and should take account of the applicable data protection obligations.
Incentivised reviews: particular care with marketing campaigns
Initiatives that offer discounts, prizes or other benefits in exchange for reviews call for particular caution.
The Guidelines distinguish between: - incentives that influence the content of the review by steering it towards a positive assessment, which are always unlawful; and
- incentives that do not require a particular outcome. In this case, the review may be considered legitimate, provided that the consumer is clearly informed that an incentive was given, whatever the means used and the benefit granted. Incentivised reviews should also be marked with clearly visible graphic elements. Businesses should therefore review the terms of their promotional campaigns and how incentives are communicated, and avoid mechanisms likely to compromise the independence of reviews.
Manipulated reviews and outdated reviews
Review management must not artificially distort how consumers perceive a business. Practices such as buying fake reviews, manipulating ratings, or selectively displaying reviews to hide negative ones may expose businesses to challenges for unfair commercial practices.
The Guidelines also address how current reviews must be. For tourism and restaurant services, Law No. 34/2026 requires reviews to be submitted within thirty days of using the service. Businesses in these sectors should therefore review their procedures for collecting and publishing reviews, so as to avoid publishing reviews that do not meet the time limits set by the applicable rules.
From Guidelines to corporate compliance
In practice, businesses should review their procedures for collecting, verifying, publishing and moderating reviews, as well as the information provided to users and any incentive schemes or campaigns.
This review should also cover relationships with platforms and with external providers engaged to manage reviews, in order to clarify roles, responsibilities and the controls applied. It is also important that these procedures comply with personal data protection law, especially where tracking systems or automated tools are used to detect anomalous behaviour. |
