Can I offer a discount for a Google review?
Incentivised reviews are not prohibited in the UK. Concealing the incentive is. Google closes the disclosure route regardless, which means the answer is no on entirely different grounds from the ones usually given. We set out the permitted wording, the position on prize draws, and the penalty that is most often reported incorrectly.
No, not on Google. But nearly every version of that answer you will read online gets the reason wrong, and a wrong reason walks you into a different mistake later, so it is worth doing properly.
The line going round is that giving a customer money off in return for a review became illegal in the UK in April 2025. It did not. The incentive is not the banned thing. The review is.
The date still matters, because the advice has not caught up with it. Look at any British small business forum thread about getting more reviews and someone will suggest a fiver back, or ten per cent off the next visit, or a coffee on the house. It is offered kindly, by people trying to help. It was ordinary advice two years ago. It is not now.
So here is the actual wording. You should not have to take my word for this one.
What changed on 6 April 2025
The new unfair trading rules took effect that day, when Part 3 and Chapter 1 of Part 4 of the Digital Markets, Competition and Consumers Act 2024 were commenced. They bite on what you do from that date onwards. They are not retrospective. Two days earlier the Competition and Markets Authority, the government body that polices unfair trading, published its guidance on the review rules, the document numbered CMA208. It runs to dozens of pages and nobody standing behind a counter is ever going to read it, so these are the lines that settle the question.
Paragraph 13 of Schedule 20 to the Act is the review paragraph, and it bans two things in all circumstances. Submitting, or getting somebody else to submit, a fake consumer review, meaning one that purports to be, but is not, based on a real experience. And submitting, or getting somebody else to submit, a review “that conceals the fact it has been incentivised”.
Then the definition, which is where owners go wrong. A review conceals the incentive where a person “has been commissioned to submit or write the review” and “that fact is not made apparent (whether through the contents of the review or otherwise)”. Commissioning, the same paragraph says, “includes incentivising by any means”. CMA208 paragraph 2.10 lists what that covers: money, commission, discounts or vouchers, products given free of charge, which the guidance itself calls freebies, free stays, invitations to events.
Read those together and the discount is not the offence. The hidden review is.
The CMA says so itself, at paragraph 3.7, and I have not seen a single blog post repeat it. Traders may want to incentivise customers to leave a review by paying them or offering future discounts or free products, and they are, in the CMA’s own words, “free to do this”, provided they tell consumers the review has been incentivised and the review still reflects the reviewer’s genuine experience.
So the honest answer to the question in the title is not “that is illegal”. It is “that is legal on two conditions, one of which you will struggle to meet, and on Google you cannot meet it at all”.
The condition nobody mentions: the review has to be labelled as an advert
This is the part that does the work, and it is stricter than “mention it somewhere”.
CMA208 paragraph 3.5 says the reviewer must “label the review prominently as incentivised, namely, as an advert”, and that the label “should not have an ambiguous meaning or be placed where it might not be seen”. The duty attaches to the review, not to you. A note in your terms does not do it. A line in the email you sent does not do it.
Now think about where a Google review actually gets read. On a phone, in a list, three weeks later, by somebody who has never been in your shop and will never see the card by your till. A poster on the counter does not travel with the review.
For the fact to be apparent to that reader, the review would have to open with something like “advert: I was given ten per cent off for writing this”. Customers will not write that. And on the rare occasion one does, that review does you less good than no review at all.
On Google the door is shut anyway
Google’s Maps user contributed content policy does not have a disclosure route. Under fake engagement it tells merchants not to offer incentives “such as payment, discounts, free of cost goods and/or services” in exchange for posting any review. Under rating manipulation it says incentivised or biased reviews are not allowed and will be removed from Maps, including anything posted because a business offered payment, a discount or free goods. It also bans discouraging negative reviews and selectively soliciting positive ones, and bans pressuring customers to leave a review while they are still on the premises.
The CMA anticipated exactly this. Paragraph 3.4 of CMA208 notes that while publishing an incentivised review is not prohibited in itself, many publication media do not allow them, and where that is the case submitting one is “likely to be misleading”.
Which is the whole answer, really. The law gives you a narrow lawful route. Google has closed it. Disclosing the incentive on a Google review does not rescue you, it just documents that you broke Google’s rules. The stated sanction is removal of the content, and Google’s fake engagement policy applies across the whole business profile, not just the one review.
Can I run a prize draw instead?
Maybe. This is the one part where I would rather be boring than encouraging.
Footnote 8 to paragraph 2.10 of CMA208 says that offering the chance to earn a reward which does not guarantee a direct benefit for the reviewer, and it gives a prize draw as the example, is “unlikely to amount to commissioning”.
There is a real line in there. “Leave a review, get £5 back” is a guaranteed benefit in return for a review. “Every review this month goes into a draw for a £50 voucher” is a chance at one, and the CMA thinks that probably falls outside the ban.
But look at what that sentence is. It is a footnote, in guidance, using the word “unlikely”. The Act itself says commissioning includes incentivising by any means, and only a court can decide whether a prize draw sits outside that. The CMA has not said permitted. It has said probably not caught, and it has said it in the small print.
Two things it does not help with at all. If entry depends on the review being positive, or on five stars, you are no longer arguing about commissioning, you are in the fake review limb, because the review no longer reflects a genuine experience. And Google’s policy has no prize draw exception whatsoever: it bans incentives in exchange for posting any review, full stop, and separately bans selectively soliciting positive reviews.
A caution of my own on top of that. If you run one, run it properly. An actual date, an actual prize, an actual winner you can name.
What it would actually cost you, and the number most articles get backwards
Since 6 April 2025 the CMA can decide for itself that consumer law has been broken and impose a fine directly, without going to court first. That is genuinely new.
The maximum, under section 182 of the Act, is £300,000 or, if higher, 10 per cent of the business’s worldwide turnover. Read that again, because the ordering is doing something. Almost every write-up quotes the 10 per cent and stops there, which sounds almost reassuring for a shop turning over £250,000: ten per cent, twenty-five grand, survivable. That is backwards. The cap is whichever figure is higher, so for that shop the ceiling is £300,000. For an independent business the percentage is never the number that matters. The £300,000 is.
What it is not is a criminal matter. Parliament specifically excluded the review provisions from the offences in the Act, at section 237(8). Most of the other banned practices in Schedule 20 can be prosecuted. This one cannot. So nobody is going to prison over a free flat white, and anyone telling you otherwise has not read it. The risk is civil enforcement: a CMA fine or an order to put things right, or Trading Standards taking you to court.
The CMA also said, when the regime started, that fines in the first twelve months would likely be lower than in the years after. That window closed in April 2026.
A cafe handing out flat whites is not what that power was built for, and I will say so plainly. The realistic risk to a shop on Wanstead High Street is not a CMA investigation. It is smaller and more annoying than that. I will come to it.
Everyone does it and nobody gets fined, so why bother?
Fair question, and I want to be straight about the evidence. I have not found a published case of an independent high street business being fined over an incentivised review. That is not the same as knowing there has not been one. Enforcement that ends in a quiet undertaking does not necessarily surface anywhere I can read it, so if somebody tells you confidently how many shops have been fined for this, ask them where the number came from. If fear of a regulator is your only reason to stop, you will not stop.
Three reasons that hold up better.
Google removes them. Reviews that land in a cluster, from accounts with no history, in the same week the offer went on the counter, are exactly the pattern its automatic checks are built to catch. You spend the money, the reviews vanish, and there is nobody to complain to.
The person most likely to report you is the shop three doors down. Small streets have long memories and screenshots cost nothing.
Bought reviews also read like bought reviews. Twelve five-star ratings in nine days, most of them with no words in them, sitting on top of eighteen months of ordinary trade. Customers spot that far more often than owners think.
So how do you actually get reviews? Start with the honest number
Someone on UK Business Forums wrote up what most owners find, and I have never seen it put better. He set aside about an hour and a half across a week and sent 40 personal emails to past customers asking for a Google review. One review came back. It was from a friend.
Another member of the same forum, sending hundreds of emails a month, reported one or two reviews a month for the effort.
A moderator on the thread gave the reason in a single line: most people do not write reviews, so ask yourself when you last wrote one. I have put that question to owners across E11 and Leytonstone. It is usually a long pause, then “a hotel, maybe, in 2019”.
Email is not a hard channel for this. It is a bad one.
Ask at the counter, while they are still in the shop
The thing that works is the thing nobody can do for you. You ask, out loud, while the person is still holding the coffee.
Barbers have it easiest: the mirror moment, when the chair swings round and the customer says it looks good. The cafe gets it when someone says the flat white was better than usual. The dry cleaner gets it handing the suit back over the counter. Those few seconds are worth more than any email you will ever send, and they are gone by the time the door shuts.
Four things make it work.
Ask in the moment somebody says something nice. Not later, not by text, not in a follow-up.
Have the link ready before you ask. Google gives every business profile a short review link from the dashboard. Turn it into a QR code, print it small, tape it to the card machine so it sits under their thumb while the phone is already in their hand.
Ask in the first person. “Would you mind leaving me a Google review? It genuinely helps.” Not “we value your feedback”, which sounds like a call centre and gets treated like one.
Make it one named person’s job on each shift. Shared responsibility means nobody asks.
And nothing attached to it. Once the money is out of it you are asking a regular for a favour, which people grant far more often than owners expect, and Google’s rules and the CMA’s both stop being your problem in one move.
Are reviews really worth this much bother?
They are the one part of this worth your Saturday.
Darren Shaw runs the annual Local Search Ranking Factors survey, which is the closest thing this trade has to a proper measurement of what actually moves a business up the local results. Asked whether filling in every field on a Google profile, keeping the name, address and phone number identical everywhere, chasing directory listings and posting weekly updates would improve visibility, he said only one of those things affects rankings, a steady flow of reviews, and called the rest “busy work and a waste of time”.
I spent twenty years watching money disappear into that busy work, in businesses far larger than yours, with people paid well to know better. A steady flow of real reviews is the cheapest thing on that list and the only one he defends.
What to do if you are already running a discount offer
Stop today. Take down the card by the till, delete the line from the receipt footer, pull it out of the email template, and tell whoever works Saturdays, because they are the one who will still be offering it in November.
Do not try to scrub the reviews you already have. You cannot delete other people’s reviews anyway, and asking customers to take them down is a worse look than leaving them where they are. The rules are not retrospective, and the exposure comes from carrying on, not from what happened before you knew.
Then try the counter version for one week. Ten asks across one shift, tally marks on a bit of till roll, and count what has landed by Friday. Three is better than the 40 emails, and you will know exactly which conversations worked.
If you want to know whether your shop gets named when somebody asks their phone for a barber or a cafe in Wanstead, that is what the free Answer Audit checks. It takes nothing from you but the name of the business.
Matthew
Questions people ask
- Is it illegal to offer a discount for a Google review in the UK?
- Offering the discount is not itself illegal. What is banned, under paragraph 13 of Schedule 20 to the Digital Markets, Competition and Consumers Act 2024, in force since 6 April 2025, is submitting or commissioning a fake review, or a review that conceals the fact it was incentivised. The Competition and Markets Authority's guidance CMA208, published 4 April 2025, says at paragraph 3.7 that traders are free to incentivise reviews so long as they tell consumers the review has been incentivised and the review still reflects the reviewer's genuine experience. Paragraph 3.5 says the review must be labelled prominently as an advert. For a Google review the answer is still no, because Google's own policy bans incentivised reviews outright, disclosed or not.
- Can I run a prize draw for reviews instead of a discount?
- Cautiously, and only as a matter of UK consumer law. Footnote 8 to paragraph 2.10 of CMA208 says that offering the chance to earn a reward which does not guarantee a direct benefit to the reviewer, with a prize draw given as the example, is "unlikely to amount to commissioning". That is a footnote in guidance rather than the Act, and the Act says commissioning includes incentivising by any means, so only a court could settle it. It also protects you not at all if entry depends on the review being positive, because that engages the fake review limb instead. Google makes no prize draw exception: its policy bans incentives in exchange for posting any review, and separately bans selectively soliciting positive reviews, so it may remove them.
- Can I give a free coffee for a review if I put a sign up by the till?
- No. A free item is named in CMA208 paragraph 2.10 as commissioning a review, and the disclosure has to reach whoever reads the review. CMA208 paragraph 3.5 says the reviewer must label the review prominently as incentivised, namely as an advert, and that the label should not be placed where it might not be seen. A sign on the counter does not travel with a review read on a phone three weeks later by someone who has never been in the shop. The review itself would have to say the coffee was free, and customers will not write that. On Google it fails either way, because Google bans incentivised reviews whether or not they are disclosed.
- What is the penalty for an incentivised Google review in the UK?
- Under section 182(6) of the Digital Markets, Competition and Consumers Act 2024 the maximum penalty is £300,000 or, if higher, 10 per cent of the business's worldwide turnover. Note the "if higher". For an independent shop it is the £300,000 that bites, not the percentage. This is civil enforcement, by the Competition and Markets Authority directly since 6 April 2025 or by Trading Standards through the courts. It is not a criminal offence: section 237(8) of the Act excludes the review provisions from the offences in section 237, so nobody is being prosecuted for a free flat white. For a single high street shop the realistic consequence is smaller and quicker anyway. Google removes incentivised reviews, and a competitor on the same street can report the offer at no cost to themselves.
- How many Google reviews should I expect from asking customers?
- Fewer than you think if you ask by email. One UK business owner documented spending around an hour and a half sending 40 personal emails to past customers and getting one review back, from a friend. Another reported one or two reviews a month from sending hundreds of emails. Asking face to face, at the moment a customer says something positive and while their phone is already out for the card machine, works far better, and it is the one method a shop with a counter has that a remote agency cannot copy.