At a glance
- State whether and how reviews are verified
- Fake and paid reviews are always prohibited
- Test seals only with source and up to date
Reviews and seals are among the strongest purchase signals. Since May 2022, express duties apply to businesses that make consumer reviews available.
Displaying reviews
- Transparency (Section 5b(3) UWG): state whether and how you ensure that reviews come from consumers who actually used or purchased the product.
- No claim without checks (Annex no. 23b): claiming genuine reviews without reasonable verification is prohibited.
- No fake or manipulated reviews (Annex no. 23c): submitting or commissioning fake reviews or misrepresenting genuine ones – e.g. hiding negative reviews – is prohibited.
- Incentivised reviews must be labelled.
Star ratings
Advertising with an average rating does not require a breakdown by star category, but the total number of reviews and the period covered must be stated (BGH, 25 July 2024, I ZR 143/23).
Test results and seals
Permitted if the product is identical to the one tested, the source is easy to find, the result is not outdated, it is presented fairly relative to other results, and the tester’s licence terms are observed. Strict standards apply to paid awards: the BGH held in 2026 that awarding test seals to doctors for a fee is a commercial practice and that health-related test logos may mislead if their limits are not apparent (BGH, 30 July 2026, I ZR 130/25). Since 27 September 2026, sustainability labels must be based on a certification scheme or established by public authorities.
Case examples
A publisher licensed “top physician” seals to doctors for a fee. The BGH held in 2026 that awarding such seals for payment is a commercial practice and that health-related test logos without visible limitations can mislead (30 July 2026, I ZR 130/25).
A retailer instructs an agency to post positive reviews from changing accounts. Commissioning fake reviews is on the blacklist.
A shop displays “4.8 stars” without stating whether and how it verifies that reviews come from real buyers. Since 2022 this information is mandatory (§ 5b(3) UWG).
AI-generated reviews
Reviews generated by AI without a genuine customer experience are fake reviews. AI summaries of reviews must reflect the actual distribution. See AI in advertising.
