Online reviews are often treated as a marketing metric. For financial services firms, that is no longer good enough.
Reviews influence where consumers place their savings, arrange insurance, take out credit and choose financial products. If that picture is distorted by fake reviews, undisclosed incentives, selective moderation or misleading star ratings, the consequences extend well beyond reputation.
This is now a material regulatory and conduct risk.
Under the Digital Markets, Competition and Consumers Act, fake reviews and concealed incentivised reviews are banned practices. Businesses publishing reviews or review information must take reasonable and proportionate steps to prevent and remove misleading content. The CMA can impose penalties of up to 10% of global turnover for breaches of consumer law and has already moved from guidance into active enforcement.
Financial services firms face an additional layer of exposure. The FCA’s Consumer Duty requires firms to support customers in making effective, properly informed decisions and to communicate in ways that are fair, clear and not misleading. Reviews, ratings and testimonials may shape those decisions, whether they appear on a firm’s own website or on a third-party platform.
The risk is not limited to deliberately buying fake reviews. It can arise through poorly governed staff incentive schemes, pressure on customers to leave positive feedback, undisclosed rewards, selective invitations, suppression of negative experiences or over-reliance on a review platform’s controls.
A credible response should therefore go beyond publishing a policy.
Firms should understand how reviews are generated, where they appear, who is encouraging them and whether incentives are involved. They should test review data for unusual patterns, assess whether ratings accurately reflect customer experience and establish clear ownership across marketing, compliance, risk and customer operations.
They should also maintain evidence of the controls applied, the issues identified and the action taken. Supplier assurance alone is unlikely to provide a complete defence if the firm cannot demonstrate its own oversight.
For boards and risk committees, the central question is simple: can we evidence that the customer picture being presented is genuine, balanced and properly governed?
If the answer is uncertain, this should be treated as a live conduct, regulatory and reputational risk, not just a marketing problem.
Andrew Winton and Daniel Mohacek are from TruthEngine®. TruthEngine helps organisations independently assess online review risk, identify suspicious patterns and build a defensible, evidence-based compliance response. (Sources: Risk Coalition, CMA fake reviews guidance, FCA Consumer Duty guidance.)