Retailers and service businesses: the rules that govern customer reviews
A review posted by an employee who does not disclose their connection to the business misleads consumers, and the rule also covers testimonials on social media. The risk is not theoretical: the Competition Bureau is actively investigating online reviews and their effect on product rankings.
- The Competition Act prohibits making any form of false or misleading representation to promote a product, a service or a business interest. A review is one.
- The Bureau has a name for the practice: astroturfing, meaning representations disguised as authentic experiences or as the opinions of impartial consumers.
- The disclosure obligation covers all types of reviews and ratings, including testimonials posted on social media by employees or their relatives.
- Curating the reviews you display to show only the best can create a misleading general impression, even if each review taken on its own is authentic.
- A minimal compliance program, a written policy plus training, costs a few thousand dollars. That is nothing compared with the cost of an investigation.
On this page
What is astroturfing
Astroturfing is the Competition Bureau's name for the practice of creating commercial representations disguised as authentic experiences or as the genuine opinions of impartial consumers, such as fake testimonials or fake consumer reviews. It falls under the false or misleading advertising provisions of the Competition Act, regardless of the channel used.
What is prohibited, and it is broader than you think
We are writing here for the owners and managers of retail businesses, service businesses and online stores that solicit, display or manage customer reviews. It describes the federal framework and does not replace legal advice.
The starting point is broad: the misleading advertising provisions of the Competition Act prohibit making any form of false or misleading representation to promote a product, a service or a business interest.
A customer review is a commercial representation under this rule as soon as it serves to promote. A text written by a person rather than by the business does not escape the framework for that reason.
The Competition Bureau has a name for the problematic practice: astroturfing, which consists of creating commercial representations disguised as authentic experiences or as the genuine opinions of impartial consumers. The test is not whether a specific fact is false; it is the general impression created.
The general impression test makes a defence based on the accuracy of each element useless. A review page where every testimonial is authentic, but whose selection never shows an unhappy customer, can create a misleading general impression. That is the point most businesses have never examined.
The case of employees and relatives
It is the most common situation and the easiest to fix.
The Bureau has warned businesses about reviews posted by their employees without disclosing their connection to the business concerned. The reasoning is simple: buyers assume reviews come from real, impartial customers, and that assumption is betrayed when the author works for the business.
Two details widen the scope. The obligation covers all types of reviews or ratings, including testimonials posted on social media. And liability can reach any person or business that writes, or authorizes the writing of, reviews that create a false or misleading impression, which includes a manager who encourages the practice without writing a word.
Disclosure, on the other hand, is risk-free: an employee can share an opinion if they clearly state their business connection. The Bureau in fact recommends two measures: train employees to disclose their connections properly, and put a compliance program in place.
Offering something in exchange for a review
The question comes up on every online retail project, because the practice is widespread.
Two principles to remember: disclose the incentive, and attach no conditions to it. A review obtained in exchange for a discount, a draw or a free product, without that incentive being visible to the reader, turns a testimonial into a disguised commercial representation.
More problematic still: making the incentive conditional on the content of the review. Offering a discount only to those who leave five stars manufactures an artificial distribution, that is, a set of ratings that no longer reflects the real experience of your customers, which is exactly what the notion of astroturfing targets.
The defensible practice is to solicit reviews neutrally from all your customers, with no rating condition, and to disclose any incentive clearly, right next to the testimonial. Have your exact mechanics validated, because the nuances matter here more than anywhere else.
Choosing which reviews you display
It is the most overlooked point and the one that touches the most honest businesses.
Displaying a selection of testimonials on your site is normal. The problem appears when the selection is systematic enough to create a general impression that the real picture does not support. A business whose public rating is 3.4, and whose site shows nothing but glowing testimonials, sits in an uncomfortable zone.
The Bureau is also interested in how reviews influence product rankings and display. It has obtained court orders as part of an investigation covering, among other things, representations that could be influenced by reviews and ratings, and their effect on how products are ranked and displayed.
The safest practice is also the most commercially effective: display the real rating and the total number of reviews, rather than a selection without a denominator, that is, without the total number of reviews the rating rests on. A professional buyer gives more weight to a 4.3 rating over 380 reviews than to six perfect testimonials without context.
Testimonials that promise a result
A testimonial that asserts a result becomes a performance claim, that is, a commercial statement about the effectiveness or results of a product, and performance claims carry an additional requirement.
The Bureau regularly reminds businesses that such claims must be based on adequate and proper testing, performed before the claim is made. That requirement does not disappear because the statement comes out of a customer's mouth.
Concretely, a testimonial like 'their product doubled our sales' used in advertising commits you. If you cannot support that the result is representative, promotional use becomes risky even if the customer really said it.
The wording that holds up describes an experience instead of promising a result, and it gives the context: the industry, the period, the starting situation. It is the same scope discipline you apply to any figure.
What the risky practice costs
Three costs, and the first is not the most frequent.
The regulatory risk. The Bureau investigates, obtains court orders and imposes penalties. A targeted business absorbs legal fees, management time and a public correction, before any penalty at all.
The cleanup cost. Removing undisclosed employee reviews, rebuilding a testimonial page and redoing the campaigns that used them easily adds up to dozens of hours, with no commercial gain in return: a pure expense.
The credibility cost. A customer who recognizes an employee in a review talks about it, and the damage in a regional market far exceeds the value of the reviews in question. On a big-ticket product, losing a single sale wipes out years of marginal gain, the small extra sales those reviews bring in.
Compare that with the cost of prevention: a written policy and team training represent about thirty hours, roughly $2,400 at your internal rate, once.
The minimal compliance program that removes almost all of this risk holds in six measures.
A one-page written policy. Who can post a review, under what conditions, with what disclosure. It covers employees, their relatives, suppliers and partners.
Short training at hiring. Fifteen minutes is enough. The most common cause is not malice; it is the ignorance of an enthusiastic employee.
Neutral, systematic solicitation. Every customer, no rating condition, the same message. It is also what produces the most credible distribution.
Disclosure of any incentive. Visible, in plain language, next to the testimonial.
Displaying the real rating with its denominator. Rather than a selection without context.
An annual review of the testimonials used in advertising. Those that promise a result are the most exposed and the easiest to forget online.
Six measures, one day of work in total, and the everyday risk stops being a blind spot.
One nuance matters for professionals governed by a professional order: several codes of ethics prohibit testimonials outright, as we explain in our article on advertising rules for regulated professionals.
Five things to verify this week
The responsibility belongs to the business, including for what an employee posts on their own initiative. These five checks take half a day.
- Do you have a written policy stating who can post a review and with what disclosure?
- Have employees, relatives or partners already posted reviews without disclosing their connection?
- Is your review solicitation neutral, or does it depend on the customer's presumed satisfaction?
- Do the testimonials used in your ads promise a result you can support?
- If a non-compliant review is spotted, who removes it, within what time frame, and who documents the correction?
The useful answer names a policy and a person responsible. A weak answer says the reviews come from customers. A vendor who offers to get you reviews in exchange for a rating-conditional discount exposes you, and you are the one who will answer for the practice, not them.
Taking stock of your reviews and advertising testimonials is part of what we cover in a paid audit.
What never gets delegated: the internal policy, employee training and the decision to remove a review. What can be delegated: the inventory of existing reviews and testimonials, the neutral solicitation mechanics, the rework of testimonial pages and the annual review of your ads. A business that writes its one-page policy and trains its people at hiring never runs into this problem. A business that discovers after the fact that three employees posted glowing reviews has to remove, correct and explain, at a cost with no commercial return.
This point sits inside the plan described in building the marketing budget.
Building a reputation that rests on proof rather than staging is at the heart of the Attract customers with SEO and AI goal.
Do your reviews mainly serve online sales? See our work in ecommerce.
Frequently asked questions about customer reviews
Can an employee leave a review of our business?
Yes, if they clearly disclose their connection to the business. The Competition Bureau has warned against employee reviews posted without that disclosure, because buyers assume reviews come from impartial customers. The obligation covers all types of reviews, including testimonials on social media.
Can we offer a discount in exchange for a review?
The principle: disclose the incentive and attach no conditions to it. An incentive offered to everyone, with no rating condition, and disclosed clearly next to the testimonial is far more defensible than a discount reserved for those who leave five stars. That second practice manufactures an artificial distribution, which is exactly what the law targets.
Can we remove negative reviews from our site?
The risk is not removing one review in isolation; it is the general impression created by the selection. A site that shows only perfect testimonials while the public rating is clearly lower puts itself in an uncomfortable zone. Displaying the real rating with its total number of reviews is safer, and usually more convincing.
Is a testimonial that announces a result a problem?
It becomes a performance claim, subject to the requirement of adequate and proper testing performed before the claim is made. The fact that the sentence comes from a customer does not release you. Describe an experience with its context, industry, period and starting situation, rather than promising a result.
Are we responsible for what an employee posts on their own?
Liability can reach any person or business that writes, or authorizes the writing of, reviews that create a false or misleading impression. That is precisely why the Bureau recommends training and a compliance program: they demonstrate that the business neither encouraged nor tolerated the practice.
What should we do if we find non-compliant reviews?
Have them removed, document the correction, and put the policy in place the same month. The cleanup cost runs to dozens of hours with no commercial gain, which is the best argument for installing prevention before rather than after. Have the delicate cases validated by legal counsel.
- Competition Bureau of Canada, The Deceptive Marketing Practices Digest, Volume 3, consulted in July 2026. Source for the definition of astroturfing.
- Competition Bureau of Canada, News release of June 12, 2024 on the investigation into Amazon's marketing practices, consulted in July 2026. Source for the scope of the misleading advertising provisions and for the Bureau's interest in the effect of reviews on rankings.
- Competition Bureau of Canada, January 2024 warning about reviews posted by employees without disclosure of their business connection. The release was relayed by the Quebec business press, and its content is reported here from that relay rather than from a direct reading of the release.
- Falia working framework, arithmetic for the cost of a minimal compliance program. The amount is an explicit working example, to be redone with your internal rate.
Geneviève puts the strategy for your engagement into action. She leads all our web development projects: Shopify, WordPress and the new ways of building a site with AI. She manages our team of developers and translates your business needs into technical language. She runs your organic search (SEO), your visibility in AI answers (GEO) and your site's conversion rate optimization (CRO). Her work is at the heart of three goals: Attract customers with SEO and AI, Improve your site's conversion, and Strengthen your visibility in AI answers. With Gabriel, she also builds the landing pages for your advertising campaigns. She writes mainly about SEO, AI visibility and web design.
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