Platforms must disclose the main ranking parameters and how they ensure review authenticity. Paid rankings must be labelled.
Legal framework
- § 5b(2) UWG: main ranking parameters on marketplaces
- § 5b(3) UWG: whether and how review authenticity is ensured
- Annex Nos. 11a, 23b, 23c: paid rankings, authenticity claims without verification, fake reviews
- Art. 5 P2B Regulation, Art. 27 DSA
Case law
- BGH, 25 July 2024, I ZR 143/23 – star ratings require total number and period
- CJEU, 8 May 2025, C-697/23 – portal and compared providers are usually not competitors
Case examples
Comparison portal with commissions
A portal ranks only providers that pay commissions without saying so. Misleading.
“Verified reviews”
A shop claims all reviews are verified but performs no checks. Blacklisted.

