Digital Markets, Competition and Consumers Act 2024: What accountancy firms need to know about publishing client reviews

Accountants who publish client testimonials should be aware of the Digital Markets, Competition and Consumers Act 2024 (DMCC) which introduced strict rules regarding how client reviews and testimonials should be managed and published.

The DMCC introduced widespread changes to UK competition and consumer protection. A significant change relates to the way businesses must handle and publish client reviews. The DMCC introduces new controls to ensure that reviews and testimonials are not misleading, untrue or cherry picked. This is important for accountancy firms who use client testimonials on their websites, social media and corporate brochures.

The DMCC came into force on 6 April 2025 with a grace period of three months (i.e. until 6 July 2025) in respect of the new consumer protection rules – including the ban on fake or misleading reviews.

What does the law say?

The DMCC bans the following:

• Posting or commissioning fake reviews.
• Hiding or failing to disclose incentives behind reviews (e.g. a discount offered to a client in return for feedback).
• Presenting reviews in a misleading way e.g. by suppressing negatives or giving undue prominence to positives.
• Ignoring fake or suspicious reviews. (‘Reasonable and proportionate steps’ must be taken to stop them).

What does this mean for accountancy firms?

If your firm uses client testimonials, you should be complying with the DMCC.  A testimonial is not limited to a simple statement such as ‘Jack completed the tax return in record time’ but would also include comments in blogs, information in a video or posts on social media. It would also include endorsements included in presentations to potential clients.

If you use testimonials and reviews then you should ensure:

• The person making the review was really a client.
• You can prove the statement was made e.g. that the feedback was actually given to you.
• That you received the client’s consent to use their feedback, especially if their name is used.
• You do not edit the review in a way that changes its meaning.
• If you only show some reviews then you should make sure they present the overall feedback and not just selected examples.

Practical steps

To ensure compliance with the DMCC, firms should familiarise themselves with the rules and guidance. You could consider the following practical steps:

• Collect reviews from your clients properly, by using a standard template which also includes the provision of client consent to publicising their review.
• Keep a record of all your client reviews and consents.
• Don’t cherry pick your reviews.
• Regularly review your client testimonials to make sure they remain relevant and up to date.
• Remove what you cannot verify.

What if you get it wrong?

The DMCC is enforced by the Competition and Markets Authority (CMA). It can impose significant fines for breaches. It can also publicise its enforcement decisions which can damage reputation. This means that compliance with the DMCC is something you want to embed in your business now. You should also ensure that your marketing teams are fully trained on the rules.

How does this relate to the ICAS Code of Ethics?

The ICAS Code of Ethics already requires accountants to maintain high standards in their marketing and promotional activities. The Code of Ethics also requires members to comply with all relevant laws. Accountants should therefore view compliance with the DMCC both as a requirement of law as well as a requirement in order to uphold the Code of Ethics.

Where can I find out more?

The CMA has provided helpful guidance for businesses CMA208 - Fake reviews guidance. There is also shortened guidance on fake reviews available from the CMA. 

More information can also be found in the ICAS Code of Ethics helpsheet: Marketing Professional Services.