New EU laws on reviews - What they mean for businesses using Trustpilot

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May 2022

New laws on transparency around reviews came into force on May 28, 2022, which implement the EU's Enforcement and Modernization Directive 2019/2161 (or ‘Omnibus Directive’).

At Trustpilot, we put trust and transparency at the heart of everything we do and we’ve been following the developments closely.

To sum it up: 

  • New EU laws mean businesses need to be more transparent about reviews they display
  • The new laws don't mean all reviews have to be verified
  • We've introduced product changes to help businesses meet the requirements

What are the new rules?

In 2018, the EU adopted a “New Deal for Consumers” to strengthen EU consumer protection in the digital era. This work included a new “Omnibus Directive”, passed in 2019, which EU Member States were required to implement so that new requirements could start to come into effect from May 28, 2022.

The new rules primarily require businesses who provide access to consumer reviews of products to do the following:

Be transparent

Clearly inform consumers whether or not procedures ensuring the authenticity of reviews are in place and how the checks are made.

  • "Whether", in this context, means that businesses need to clearly display information about whether they've ensured that reviews come from consumers who have bought or used the products. If no procedures are taken, they need to display this.
  • "How" means that if processes are in place to ensure the authenticity of the consumer reviews, readers of reviews should be informed clearly. This includes stating whether all reviews - positive and negative - are published.

Don’t mislead consumers

Don’t state that reviews of a product were submitted by actual consumers if no reasonable and proportionate steps were taken to ensure that this is the case.

Such steps can include:

  • Verifying the reliability of the person posting a review (e.g. with information to show they have used/purchased the product)
  • Asking for a booking number
  • Requiring reviewers to register to post a review
  • Using technical means to verify the reviewer is a consumer
  • Having clear rules prohibiting fake and undisclosed incentivized reviews
  • Using tools to detect fraud
  • Taking adequate measures to address complaints about suspicious reviews

What's considered proportionate won't be the same in all circumstances.

Do all reviews have to be verified?

No. Unfortunately, there’s a lot of misguided advice out there. We’ve seen online articles and information that oversimplify the new EU legislative requirements, and make inaccurate statements such as “you need to verify that your reviews are genuine”. This is not correct. Businesses don’t have to verify all reviews or “gate” the collection of reviews so that only people who have made a purchase can write them.

Rather, the purpose of the new rules is to inform consumers about any procedures in place to ensure the authenticity of reviews about products, and what these procedures are. Transparent information will empower consumers to decide how much weight to give to the reviews they’re reading.

At Trustpilot, we welcome new rules that protect consumers, since this aligns with our mission of enhancing trust online. We also acknowledge that the focus on transparency rather than documentation underlines the benefits of open platforms (such as Trustpilot), which let consumers share their experiences at any time, without waiting for an invitation. We collect service reviews from everyone who has had a genuine experience - not just a purchase - and this full and holistic feedback provides vital insight into a range of experiences, which businesses can use to learn from and improve.

What does this mean for reviews collected using Trustpilot?

We collect two main types of reviews: service reviews and product reviews. The new rules concern “consumer reviews of products”, which specifically highlights reviews about products.

Product reviews Service reviews
Reviews about products and their attributes collected via an add-on product reviews module for Trustpilot’s paid services. These are the reviews written about experiences with businesses and those we display on our main website.
Available to paying customers only. Available to businesses using our free services, as well as our paying customers.
Reviews are displayed on businesses' own websites. Reviews are displayed on Trustpilot, and can be showcased on business websites via our widgets.

See the different reviews we collect here.

Our safeguards for product reviews

Reviews collected via our product reviews module let businesses send invitations to customers at the most relevant point in the buying journey, adjusting for delivery time if necessary. This ensures that real customers are sent invitations to review products because they have partially or fully completed a purchase.

We mark reviews collected in this way as “verified”, since our process means that there is a level of confidence that reviews are likely to be from genuine customers having purchased a product.

We’ve also made changes to the featured wording in our product review widgets to state that the reviews are “verified” reviews from Trustpilot. We’ve also made sure our logo is clearly displayed, so viewers know the reviews have been collected via Trustpilot. Readers of these reviews can click on a link to read further information that clearly and transparently explains how reviews are collected using our services.

Image of a product review

Our safeguards for service reviews

All of the service reviews we host on our consumer website are subject to the safeguards we already have in place to ensure the integrity of reviews.

The new rules set an expectation for businesses to take “reasonable and proportionate steps”, and we already have such steps in our processes and platform, such as:

  • 100% of reviews are run through our fraud detection software
  • Reviewers must create an account on Trustpilot to write a review, using a real and permanent email address
  • To post a review, reviewers must tick a box to confirm that their review is about their own genuine experience and that they are eligible to review the business. This step links the reviewers to our guidelines and reminders on who can write a review and when
  • Reviews we collect are labelled - for example, as “verified” if they are collected in response to an invitation triggered via our automatic invitation systems. We make it easy for readers to understand how all the reviews for a business have been collected via the Company activity page, accessible from every business profile page
  • Our consumer verification option lets consumers verify their account with us to show that they are who they say they are, and we highlight verified consumers by displaying a green tick next to their username
  • Reviews must comply with our guidelines, which clearly prohibit fake and incentivized reviews
  • Consumers or businesses can make complaints about suspicious reviews, including if they are not submitted by genuine consumers, and we will investigate
  • We provide links to information about platform safeguards and how reviews are collected on each page that displays a business’s reviews. 

If a business displays service reviews on their website using our widgets, they include wording that allows readers to click through to Trustpilot. From there, you'll be able to see the review labels and find information about how we work, as well as about the safeguards mentioned above.

What should businesses do to comply?

Businesses should ensure that the information they display concerning reviews is as clear as possible for consumers. Since transparency is at the core of what we do, we’ve already done much of the work here.

But extra considerations to keep in mind include:

  • Businesses who showcase reviews using our services should ensure they have implemented our widgets correctly, including using the most up to date versions. These will automatically update when changes are released. However, businesses that have implemented a custom widget using our API will have to update these manually when new versions are released. Businesses will be notified of new versions via customer communications, or in Trustpilot Business.
  • Businesses can consider providing readers of reviews with additional information, such as stating “We collect reviews using Trustpilot.”
  • Businesses can also link to information from our Help Center. This could be, for example, with a statement “See how Trustpilot reviews are collected”, “Understand Trustpilot’s review labels” or “See how Trustpilot safeguards reviews”.

A final word

At Trustpilot, we’ve spent years investing considerable resources to preserve the integrity of the content on our platform; it's in our interests to do so. If consumers and businesses are unable to trust the feedback they see there, public confidence in our platform would be undermined. We’re confident that the steps we’ve already put in place, and the information we have available go a long way towards helping businesses meet the requirements.

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