Consumer protection

Online reviews: the Competition Authority issues guidelines to ensure transparency

The tools made available to tackle irregularities include QR codes, OTP codes and AI. They are not limited to the tourism and catering sectors

by Camilla Curcio

Deemerwha studio - stock.adobe.com

4' min read

Translated by AI
Versione italiana

4' min read

Translated by AI
Versione italiana

The Competition Authority, the competition and market regulator, has launched a public consultation on the ‘Draft Guidelines aimed at guiding businesses in adopting appropriate measures to ensure compliance with the legality requirements for online reviews ’. This has been confirmed by Assoutenti, which has highlighted the main changes for consumers set out in the AGCM document published on 30 June. This document, on the one hand, is in line with the approach reiterated in Law 34/26 (also known as the SME Act) regarding the hospitality and tourism sector, whilst on the other hand it aims to provide businesses with clear guidance on interpreting the provisions of the Consumer Code relating to reviews. Comments and ratings which, for some users – who often haven’t even purchased the item being reviewed – become (erroneously) a means of mockery or pranks, risk becoming the spark that ignites significant reputational crises for industry professionals.

Who are the Guidelines intended for?

The Guidelines are not only aimed at tourism operators and the catering sector but to all professionals – wherever they work – who direct their commercial activities towards Italia and provide features or services that enable the publication of reviews online: therefore, this scope includes both professionals who supply goods or services intended to become the subject of evaluation, and those who offer platforms and systems for publishing or managing reviews of goods or services sold and/or provided by third parties.

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As stated in the text, ‘professionals should provide consumers with clear and easily accessible information on how reviews on their channels are published, managed, categorised and moderated’. Furthermore: “This information should be published on the same interface where users can read reviews, including via a clearly identified link.”

It is also important to set out in writing the criteria used to collect or obtain reviews, those used to select them for publication, and the methods used to calculate scores or any other type of rating, where available.

Audit tools

The Competition Authority has drawn up a series of measures to prove that the consumer has actually used or purchased the product or service they are reviewing. And that they have therefore provided a truthful review that is 100 per cent (or thereabouts) accurate. These can essentially be divided into three types:

1) Ways to prove that the reviewed product has actually been used

(a) authentic tax or accounting documents proving the purchase or use of the product or service, or an order or booking reference number. In other words, material evidence that is virtually impossible to refute;

b) the sending – to the email address used for purchases – of a link to leave a review, only after the order has been completed, delivered or used;

c) the review can only be accessed in the customer’s private area, under the ‘Orders/Bookings/Completed Transactions’ section;

d) the collection of reviews via dedicated channels, the authenticity of which is guaranteed by the professional via QR codes and verification systems using OTP codes;

2) Tools for identifying the author of the review

(e) systems for recording the authors of comments on their own channel;

f) confirmation link sent to the email address;

g) checking the IP address ;

3) Automated tools for detecting fraudulent activity by identifying anomaly signals (including in documentation produced to demonstrate the absence of deception)

(h) the presence of several reviews posted within a short period of time from the same IP address;

(i) repetitive linguistic patterns

Generally speaking, therefore, the green light is given only to reviews written by those who have had genuine interactions with the product or the company selling it. This must often be demonstrated with evidence of the purchase or booking and the subsequent delivery.

Use of AI

To professionals who, whilst not directly selling the goods or services reviewed, host or make available comments written and posted by users, the Competition Authority has suggested that they combat the phenomenon of inauthentic reviews, not only through all the measures mentioned above and always in proportion to the provider’s size (and its business model), but ‘also by using tools based on artificial intelligence”, which would subsequently be combined with “a process of human content review”.

‘Incentivised’ reviews

Last but not least, the AGCM also urges caution regarding incentivised reviews by professionals who supply the goods or services being rated and reviewed. As stated in the Guidelines, in such cases one should ‘ensure that the content of reviews is not the result of an incentive provided by the business and guarantee that consumers are clearly informed that the reviews have been incentivised, regardless of the medium used and the benefit obtained’.

But that’s not all: the document also highlights the need – for professionals – to refrain from ‘practices designed to manipulate reviews’. This means discouraging, removing or hiding negative comments; providing pre-filled templates for positive reviews; involving the public in moderation processes in order to persuade them to amend or delete reviews already published online; producing aggregated ratings based on unknown parameters. In short, what matters is to clarify as clearly as possible the methods of data collection and the measures taken to ensure their accuracy.

Finally, it is essential to adopt measures that enable organisations to ‘keep a record of the origin of the review, the checks carried out, the risk ratings, decisions regarding publication, rejection or removal, and the handling of any complaints ’. In addition to providing clear guidance on policies for managing reviews that are out of date or irrelevant because they relate to product or service conditions that are now obsolete.

What will happen next?

By 15 July, all interested parties will be able – as part of the consultation – to submit their comments to the Competition Authority. “Despite improvements, such as the provision of a QR code to verify the authenticity of a review – a measure that responds to a specific request we made – we believe there are still too many grey areas surrounding this issue,” commented Gabriele Melluso, president of Assoutenti. “Law 34/2026 allows users only 30 days to review a product or service, and there is no provision for the involvement of consumer organisations in the fight against fake reviews.”

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