CMA launches enforcement investigation into JustEat, Autotrader and three other platforms over fake and misleading online reviews
The Competition and Markets Authority (CMA) has opened enforcement investigations into five businesses — including JustEat and Autotrader — over alleged fake and misleading online reviews. The investigations deploy new direct enforcement powers that came into force in April 2025, under which the CMA can impose fines for consumer law violations without needing to bring court proceedings. The CMA's consumer enforcement regime was substantially strengthened by the Digital Markets, Competition and Consumers Act 2024 (DMCCA), which gave the regulator the ability to take direct action — including significant financial penalties — against firms that breach consumer protection rules. Online reviews and star ratings are within scope because manipulated ratings constitute a misleading commercial practice under the Consumer Protection from Unfair Trading Regulations 2008. The CMA confirmed it has not yet reached conclusions on whether consumer law has been broken. However, opening a formal investigation is itself a significant step — it triggers mandatory cooperation obligations, document preservation requirements, and the risk of substantial fines if violations are established. CMA chief executive Sarah Cardell has publicly signalled that online platforms manipulating consumer-facing information are a priority for the regulator's new enforcement powers. The investigation is framed as a response to household budget pressure, with the CMA emphasising that consumers relying on reviews to make purchasing decisions deserve accurate information.
Why this matters
The CMA's use of its DMCCA direct enforcement powers — rather than seeking court injunctions as it would have done under the old regime — is the key development here. This is precisely the scenario the 2024 Act was designed to address: fast, regulatory-led enforcement against consumer-facing digital platforms without the friction of litigation. For platform businesses, the investigation creates immediate demand for regulatory defence work: responding to CMA information requests, advising on cooperation strategy, and assessing exposure under the new penalty regime. The 'why now' is the regulator deploying its post-DMCCA toolkit for the first time in a high-visibility consumer context, establishing precedent for how investigations of this type will proceed.
On the Ground
A trainee supporting a CMA enforcement investigation would assist with regulatory notification drafting — preparing the client's formal response to CMA information requests — help compile a compliance gap analysis memo identifying which review practices may fall within the scope of the Consumer Protection from Unfair Trading Regulations, and maintain a remediation tracker to document corrective steps taken by the client during the investigation.
Interview prep
Soundbite
The CMA's DMCCA direct enforcement powers have arrived — JustEat and Autotrader are the first major test of whether the new regime has real bite.
Question you might get
“What are the key differences between the CMA's new direct enforcement powers under the DMCCA and the previous regime for consumer law enforcement, and how does that change a client's litigation risk exposure?”
Full answer
The CMA has opened enforcement investigations into JustEat, Autotrader, and three other platforms over fake online reviews, using direct fining powers introduced by the Digital Markets, Competition and Consumers Act 2024. This matters because it is the first significant public deployment of those powers against household-name consumer platforms — establishing how aggressively the CMA will use its new toolkit. The wider picture is a deliberate regulatory escalation: the CMA explicitly said it gave businesses time to self-correct and is now moving to direct enforcement. This connects to a broader trend of UK regulators being handed sharper enforcement instruments — the FCA, CMA, and ICO are all operating with expanded powers post-2024. I expect this investigation will accelerate compliance reviews at every major UK consumer platform, generating significant regulatory advisory mandates.
My notes
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