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Customer reviews shape how potential clients find and choose your business. For online businesses especially, reviews build trust and influence purchasing decisions in ways traditional marketing never could. Managing those reviews well matters for your business reputation and for your legal compliance.
Under Australian Consumer Law, how you collect, display, and moderate customer reviews carries legal obligations. The rules aren't complicated, but getting them wrong can create problems. Misleading conduct doesn't just apply to your product descriptions or advertising, it applies to reviews and testimonials as well.
Working with business owners across Australia, I help navigate these requirements in ways that protect your business while building genuine customer trust. Let's look at what the law requires and how to manage reviews in a way that works for both your business and your customers.
Invest time in creating a clear review collection process that includes proper disclosure when offering incentives. Work with your team to ensure everyone understands what's acceptable - no fake reviews, no editing customer words, no selective removal of negatives. Document your moderation policy in writing so you can demonstrate consistent, fair treatment of all reviews. When negative reviews appear, consider them opportunities to show how you respond to concerns rather than problems to hide. This approach builds more sustainable trust than trying to present a perfect record, and it keeps you on the right side of Australian Consumer Law requirements.
The Competition and Consumer Act 2010 (Cth) includes provisions about misleading or deceptive conduct that directly affect how businesses handle customer reviews. These aren't new rules created just for online reviews—they're applications of existing consumer protection principles to modern business practices.
Conduct becomes misleading under the law when it's likely to deceive or create a false impression for consumers. This applies whether the misleading element is in your advertising, your product descriptions, or in how you present customer feedback about your business.
The Australian Competition and Consumer Commission (ACCC) provides guidance specifically about reviews and testimonials. Their focus centres on whether consumers can trust that reviews represent genuine customer experiences and whether the overall impression created by your reviews accurately reflects customer sentiment.
When potential customers research your business, they're looking at everything you present—your own claims about your services and what other customers say about their experiences. Reviews function as a form of social proof, and consumers rely on them when making decisions.
This is why the law treats manipulated reviews seriously. If you're creating fake positive reviews, suppressing genuine negative feedback, or editing reviews to sound better than the original, you're potentially misleading consumers about what they can expect from your business.
For online businesses, review compliance sits within your overall obligations under Australian Consumer Law. You're already thinking about accurate product descriptions, clear pricing, and fair terms of service. Review management is part of that same framework—representing your business honestly to consumers.
This doesn't mean you can't moderate reviews or that every negative comment must stay visible forever. It means your approach to reviews needs to be fair, transparent, and focused on presenting genuine customer experiences rather than creating an artificially positive impression.
Let me walk you through the specific requirements that apply to how you collect and display customer reviews. These come from my work helping businesses implement compliant review practices.
Reviews must come from actual customers who have genuinely used your product or service. This means you cannot write reviews yourself pretending to be a customer, ask employees to pose as customers, or pay people to write reviews without proper disclosure.
The "genuine experience" requirement also means reviewers should have enough experience with your product or service to form a meaningful opinion. Someone who received a free sample might write a review, but that relationship needs disclosure.
You can moderate reviews—removing content that's offensive, defamatory, or completely irrelevant to your business. What you cannot do is remove or hide negative reviews simply because they're unfavourable, especially when you're displaying positive reviews.
If you only publish positive feedback while consistently removing anything negative, you're creating a misleading impression of overall customer satisfaction. The law requires balance. Consumers need to see a reasonably accurate picture of what other customers experienced.
When you display a customer review, it needs to reflect what the customer actually said. You cannot edit reviews to make them sound more positive or to remove criticisms while keeping praise.
There's some flexibility for formatting—shortening a lengthy review to fit your layout, for instance. But if you shorten or edit reviews, you must ensure the edited version doesn't change the customer's actual sentiment or create a misleading impression.
Transparency about relationships matters. If you've offered any incentive for a review—a discount, free product, entry into a prize draw, or any other benefit—that needs disclosure alongside the review.
The disclosure should be clear enough that consumers understand the relationship. "Reviewer received a discount in exchange for honest feedback" works. Simply stating "verified purchase" when the customer actually received a discount doesn't meet the requirement.
This extends beyond just your customers. If you've engaged influencers, provided free products to reviewers, or have any other commercial relationship with someone writing about your business, those relationships need disclosure.
Even when reviews appear on platforms you don't control—Google, Facebook, industry review sites—you can still have responsibilities. If you become aware of misleading content and you have the ability to address it, the law may expect you to take reasonable steps.
This doesn't mean you're responsible for every review on every platform. But if you're actively using a third-party platform, monitoring it, responding to reviews, and a fake positive review appears, taking it down or flagging it for the platform shows you're acting reasonably.
Let me share what I typically recommend when business owners want to establish review collection and management practices that protect their interests while meeting legal requirements.
Document what reviews you'll accept and under what circumstances you might remove content. Your policy might address offensive language, defamatory statements, reviews from non-customers, spam, or content that violates privacy.
The key is consistency. If your policy says you remove reviews containing profanity, you need to actually do that across all reviews, not just negative ones. Document why reviews were removed—this creates a record showing you followed your stated policy rather than selectively removing unfavourable feedback.
When you ask customers for reviews, make it clear if there's any incentive involved. If you're offering a discount on future purchases for leaving a review, say so in the request and ensure the disclosure appears with the published review.
Many businesses use email templates to request reviews. Build your disclosure language directly into those templates so it's automatic, not something you need to remember each time.
Everyone who touches your review process needs to understand the rules. That means your marketing team, customer service staff, and anyone else who might be tempted to post a "helpful" fake review or edit customer feedback.
Make it clear that reviews must be genuine, editing isn't acceptable, and selective removal based on sentiment creates legal risk. When your team understands why these rules exist—to protect the business—they're more likely to follow them.
Where possible, verify that reviewers actually purchased or used your product or service. Many platforms offer "verified purchase" indicators. Using these systems helps demonstrate that your reviews come from genuine customers.
If you're collecting reviews directly on your own website, consider implementing a verification system that links reviews to actual transactions or service delivery.
When negative reviews appear—and they will for any business with reasonable volume—your response matters more than the review itself often does. Potential customers reading reviews want to see how you handle problems.
Responding professionally, acknowledging the customer's experience, and explaining how you've addressed the issue shows that you take feedback seriously. This is far more persuasive than a wall of perfect five-star reviews with no business responses.
Set aside time quarterly to review how you're managing customer reviews. Look at what you've removed and why, check that disclosures are appearing where they should, and verify that your team is following your documented policies.
This regular review process helps catch problems before they become compliance issues and demonstrates that you're taking your obligations seriously.
Consider an online retailer selling homewares who implemented what seemed like a reasonable review system. They collected reviews by sending follow-up emails to customers offering a 15% discount code for their next purchase if they left a review.
The business displayed all positive reviews immediately on product pages. Negative reviews went into a queue for "quality checking" where the owner personally reviewed them. Reviews containing any criticism were often deleted for being "not constructive" or "unhelpful to other customers."
After six months, the business had hundreds of four and five-star reviews displayed, with almost nothing below that. They genuinely believed they were doing the right thing - removing "unfair" criticism and only showing reviews that would help customers make informed decisions.
When questions arose about their review practices, several problems became apparent. First, they weren't disclosing the discount incentive with the reviews - customers reading the reviews had no idea reviewers received benefits for participating. Second, their "quality checking" process effectively filtered out negative sentiment while publishing positive feedback automatically. This created a misleading impression of customer satisfaction.
The business wasn't trying to deceive anyone. They thought they were moderating reviews fairly and protecting their reputation from unreasonable complaints. But the law looks at the overall effect - were consumers getting an accurate picture of customer experiences?
Working together, we implemented a compliant system: disclosure of the discount incentive appearing with all reviews, a documented moderation policy focused on genuinely problematic content rather than negative sentiment, and automatic publication of all reviews that met the policy criteria regardless of star rating.
Within weeks, their review profile looked more balanced - still predominantly positive, because they ran a good business, but including some criticism and lower ratings that gave the overall picture more credibility. Customer trust actually improved, and they were operating within legal requirements.
This situation illustrates a common pattern. Businesses often create compliance problems not through deliberate deception but through misunderstanding what's acceptable. The solution is usually straightforward once you understand the requirements.
Steps to take now:
Set up your review collection process with proper disclosure built in from the start. This means your email templates, review request forms, and any other ways you gather feedback should include clear disclosure if you're offering incentives.
Document your review moderation policy in writing. Cover what types of content you might remove and ensure the policy focuses on genuinely problematic content rather than negative sentiment.
Audit your existing reviews to ensure any incentivised reviews include proper disclosure and that your display of reviews doesn't create a misleading impression by selectively showing only positive feedback.
Train anyone who touches your review process on what's acceptable and what isn't. Make it clear that fake reviews and selective removal of negatives create legal risk.
Red flags that suggest you need to revise your practices:
You're removing negative reviews routinely while publishing all positive reviews—this selective filtering likely creates misleading impressions.
You or your staff have posted reviews pretending to be customers, even with good intentions. This needs to stop immediately and ideally such reviews should be removed.
You're offering incentives for reviews but not disclosing this relationship where reviews appear—add disclosure now to all existing and future reviews.
You're editing customer reviews to make them sound more positive or to remove criticism—stop editing reviews and display them as written or don't display them at all.
You're receiving questions or complaints about your review practices, or you've noticed competitors' reviews look suspicious—this is a good time to ensure your own practices are sound before similar questions come your way.
When to seek immediate professional advice:
The ACCC or another regulator has contacted you about your review practices. Don't wait—legal advice at this stage can help protect your interests.
You've discovered significant non-compliance issues in how you've been managing reviews, especially if you've been doing this for some time. Getting advice about how to address historical issues matters.
You're implementing a new review system for your business and want to ensure it's set up correctly from the start. This is much easier than fixing problems later.
A competitor has raised concerns about your review practices publicly or threatened to report you to authorities. Professional advice helps you assess your actual position and respond appropriately.
Customer reviews are valuable for your business when they're genuine and managed in a way that builds real trust with potential customers. The legal requirements under Australian Consumer Law protect both consumers and businesses - they're designed to ensure the reviews people rely on actually reflect real customer experiences.
I work with business owners Australia-wide on day-to-day business operations including consumer law compliance. If you'd like to discuss your review collection and management practices, or if you're setting up a new review system and want to make sure it's compliant from the start, I can
Yes, you can offer incentives like discounts, free products, or competition entries to encourage reviews. The critical requirement is disclosure—the incentive must be disclosed clearly where the review appears. The incentive shouldn't be conditional on leaving a positive review specifically; it should be offered for honest feedback regardless of rating.
You can and should remove content that's defamatory, false, or violates your documented moderation policy. The key is having that policy documented and applying it consistently. For potentially defamatory content, consider seeking legal advice before removal as defamation has specific legal meanings.
You're not automatically responsible for every review on third-party platforms. However, if you're actively using these platforms, monitoring them, and responding to reviews, you may need to take reasonable steps about misleading content you become aware of.
Your policy should be specific enough that someone could apply it consistently. Rather than "we remove unhelpful reviews," say what makes a review unhelpful—for example, reviews containing profanity, reviews from non-customers, spam, defamatory content, or reviews that violate privacy.
You can ask, but you cannot pressure, incentivise, or require customers to change reviews. The safest approach is usually responding publicly to the review explaining your perspective rather than trying to get the customer to change it.
Non-compliance can lead to formal action by the ACCC, which has the power to seek penalties for breaches of consumer law. Beyond legal penalties, discovery of review manipulation damages customer trust and business reputation. If you're unsure whether your practices comply, it's worth discussing with someone who can review your specific situation.
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