Executive summary

How do consumers make choices online? The internet has long since exploded the number of available products and services, giving shoppers more choice than ever before. But that rise in choice has made guidance on purchase decisions a valuable commodity. Every day, consumers rely on the reviews and rankings of others to determine their purchasing decisions: a majority of Canadian consumers consult user-generated content, including reviews, as an essential step in their online shopping routines. More specific studies have found that reviews factor strongly into decisions for approximately 70% of consumers. The internet has birthed a thriving ecosystem of shoppers and experts offering in-depth advice for even the most esoteric of products. But something else has been growing on the underbelly of this ecosystem.

Digital platforms like Amazon and Google Maps have become polluted with fake reviews, thanks to black markets that operate in plain sight, often through other important digital platforms like Facebook. On these platforms, sellers and business owners can solicit fake five-star reviews in exchange for free products or commissions. Specialized fake review websites run similar fake review operations coordinating the actions of individuals or bots. Actors involved have developed sophisticated methods to evade detection by platforms—part of the reason why addressing fake reviews is challenging.

Fake reviews represent concrete harms for three distinct groups:

Consumers

For consumers, fake reviews obscure the true quality of a product or service, causing financial loss and decreasing the trust in reviews overall. In the most serious cases, fake reviews can lead consumers towards potentially dangerous products or services.

Honest sellers

For honest sellers, fake reviews purchased by their competitors put them at a clear disadvantage and obstruct them from competing on the basis of genuine quality. With no options for recourse, honest sellers are tempted to purchase fake reviews themselves.

Platforms

For platforms, fake reviews can lead to consumer distrust, and potentially open the door for legal liability.

The policies of the platforms involved explicitly prohibit fake reviews, but there are important gaps in their enforcement. The persistence of the issue raises serious questions about the role and incentives of the platforms: whether they have a financial interest in letting it persist, and whether gatekeeping behaviours create the conditions for the fake review market to thrive.

Despite these challenges, more can be done to address fake reviews, and for Canada, the Bureau’s investigation into Amazon is just the first step. Both regulators and the platforms themselves must be involved in a strategy to comprehensively tackle fake reviews:

The problem of fake reviews undermines a key source of trust and transparency online and likely serves as a barrier to its further expansion. By building a more trustworthy online marketplace, policymakers and platforms can deliver benefits to consumers and businesses. Even the platforms themselves will reap the benefits of increased trustworthiness.

Introduction

As e-commerce becomes the default option for many consumers, the modern shopping experience has become increasingly overwhelming. Thousands of results can be generated in seconds, making it difficult to know what is trustworthy. This is where the helpful advice of other buyers who generously took the time to write reviews comes in. Online reviews help solve the information asymmetry of online shopping, making it much simpler to sort through an overwhelming list of options. The same can be said for physical businesses as much as e-commerce, where online reviews influence consumer choice and help narrow a long list of options.

For a majority of Canadian consumers, consulting user-generated content, including online reviews, is an essential step in online shopping.¹ Other surveys have similarly found that reviews factor strongly into decisions for around 70% of consumers.²

Yet the high level of trust in online reviews is perhaps misplaced given online platforms have become increasingly littered with fake reviews. Sellers and businesses across e-commerce and review aggregating platforms have been accused of purchasing fake reviews from third parties to artificially inflate their ratings. From overseas Amazon vendors who solicit fake reviews from Facebook for their cheaply manufactured low-quality products to reported instances of Canadian professional practices paying for fake Google reviews to promote their businesses, fake five-star reviews seem to be everywhere. The practice, called review brokerage, persists despite attempts from platforms and regulators around the world to curb it. Fake reviews harm firms who attempt to compete on the basis of genuine reviews, and consumers who seek out genuine advice on their purchase decisions. They also have reputational implications for platforms that host reviews.

When it is possible to game the system, review brokerage represents a real threat to competition between firms. Firms who purchase fake reviews gain an unfair market advantage over their competitors by enjoying an inflation of their average ratings. This manipulation is problematic when ratings and reviews influence not only consumer decisions, but also how platforms make recommendations and present search results to consumers. At a moment when Buy Canadian sentiment is on the rise, these barriers to fair competition for honest Canadian small and medium-sized enterprises (SMEs) are especially important. Addressing the persistence of fake reviews across platforms is essential to maintaining competition on the basis of price and quality instead of fake review arms races.

Fake reviews have clear implications for consumers. Fake reviews deceive consumers as to the true nature or quality of a product or service, making it impossible to effectively compare alternatives. When consumers inadvertently purchase products because of fake reviews, they are likely to end up wasting their money or even being harmed by counterfeit or misrepresented products.

While both marketplace and social media platforms have taken action to limit fake reviews, the question of whether their business models and enforcement choices allow the problem to persist must be raised. Because Amazon is the dominant e-commerce platform in Canada, the persistence of fake reviews there leaves honest firms with few alternatives where they can compete fairly. As is the case with fraudulent online advertising, a dollar spent on a misrepresented product is still a dollar spent on the platform.³

The same logic extends to platforms like Google Maps, which shape the in-person purchase decisions of the majority of Canadians and therefore the fate of thousands of Canadian businesses.

Their ubiquity means that Google reviews are particularly well positioned to influence consumer choice, and thereby impact competition. If fake reviews are the norm, then they become a potent vector of competition. Accordingly, competition regulators around the world are taking action against fake reviews.

Canadian policymakers must step in to protect consumers and honest sellers on platforms if we want e-commerce to continue to thrive. In some ways the solution is simple: increasing the risks of purchasing fake reviews so that they outweigh the benefits for firms. But this is easier said than done. Reviews should represent an incentive for firms to compete on the basis of high-quality products and a chance to collect valuable feedback, not an easy opportunity for exploitation. With concerted effort from policymakers, this is possible.

What are fake reviews?

Reviews and ratings are often used interchangeably, though they represent two distinct elements of the ecosystem. Reviews are the text submitted by a consumer with a corresponding rating (most often out of five). Those ratings are then aggregated into a product or service’s overall rating. Ideally, a review represents the consumer’s genuine opinion, but often that is not the case.

Broadly speaking, a fake review is any review, positive or negative, that does not reflect the genuine opinion of its author. This definition encompasses many different types of review fraud, which contribute to an overall decline of the online shopping experience for consumers and competitors alike. While the focus here is review brokerage—when a firm solicits fake positive reviews from a third party in exchange for a free product or a commission—it is useful to define other relevant types of fake reviews.

Review bombing

When a product or service is inundated with negative reviews, typically for political or ideological motivations. Review bombing occurs across products and services, including film, gaming, literature and other industries.⁵ Review bombing can even take the form of extortion scams, where payments are demanded to remove the negative reviews.⁶

Astroturfing

When a business purchases or otherwise incites positive commercial representations online about its own product or service. Astroturfing does not necessarily happen through reviews, though they provide a useful vehicle for misleading representation, which is one key distinction from review brokerage. Astroturfing also often involves people affiliated with a business masquerading as genuine unbiased consumers in order to promote it.⁷

Suppression of negative reviews

When sellers delete or otherwise obscure negative reviews in order to give greater weight to positive ones. While there are technically no fake reviews written, it is still a deceptive tactic by which firms can game review systems in order to inflate their rankings. Firms can also effectively suppress negative reviews by making it difficult for consumers who had bad experiences to write a review in the first place.⁸

How does ‘review brokerage’ work?

Breaking down how review brokerage works reveals that fake reviews are highly accessible and fairly inexpensive, via numerous different pathways, for firms looking to exploit the system.

Review brokerage occurs on platforms where a firm is not directly responsible for aggregating the reviews it receives: on review aggregators or on e-commerce marketplaces. Review aggregators collect and host reviews externally to where the object of the review is being sold. Review collection is typically a core, if not sole, function of their business model: Goodreads or Letterboxd, for example. However, it is the platforms designed for reviewing brick-and-mortar service-based businesses—Google Maps, Yelp, Tripadvisor and even Facebook—that are the primary target for review brokerage. E-commerce marketplace platforms are responsible for managing the reviews for the third-party sellers they host. It is these third-party sellers who purchase brokered reviews to be inadvertently displayed by the marketplace owner—predominantly Amazon, but also others like eBay, Shopify or Walmart.

In both cases, because the firms operating on these platforms are not responsible themselves for hosting their reviews, review fraud needs to find a way to work inside the platform’s official channels: hence the emergence of review brokerage.

Review brokerage involves a sophisticated black market that often operates in plain sight across the internet. There are two main channels that support review brokerage: groups operating on social media platforms, mainly Facebook, and specialized fake review websites. The review brokers running these channels are the facilitators behind the whole review brokerage operation.

Facebook groups

Facebook groups are used to generate fake reviews for a range of platforms, including both e-commerce marketplaces and review aggregators, though the ones designed for Amazon reviews have received the most study. As many of these groups are public, it is easy to gain entry and the mechanics of how they work are well understood. Researchers from the University of California, Davis, Rajvardhan Oak and Zubair Shafiq, conducted surveys with the various actors involved in the practice.⁹ This network of actors has also been the subject of a comprehensive investigation by another group of researchers, Sherry He, Brett Hollenbeck and Davide Proserpio, who mapped the economic implications of fake reviews.¹⁰ Even earlier, reporter Zachary Crockett infiltrated several fake review Facebook groups and wrote about his findings in 2019.¹¹ Using the Facebook-Amazon pipeline is therefore a useful starting point for understanding the dynamics of the fake review economy:

Step 1The product

Review brokerage begins with a third-party seller on Amazon interested in promoting a product. That seller can either then use a ‘review agent’ to find reviewers for the product, or, less commonly, find reviewers themself.¹² To find reviewers, review brokers post products they need reviewed in a Facebook group and encourage anyone interested to reach out to get the products for free. Review brokers typically post many products at once for potential reviewers to browse through. Sellers organizing reviews themselves also post in these same groups to attract reviewers.

Fake review groups can be found incredibly easily on Facebook since most are named a variation of ‘Amazon Reviewers’. There are many groups listed exclusively for Amazon.ca and calling for Canadian reviewers only, confirming the existence of the issue in Canada. In their descriptions, the groups advertise to both sellers interested in boosting their rankings and to reviewers interested in receiving free products. Agents will also purchase targeted advertisements on Facebook to recruit reviewers.¹³ Upon joining some of these Facebook groups, review agents will also reach out to a potential reviewer directly.

Step 2The review

Once a reviewer finds a product they are interested in, they reach out to the agent or seller to receive instructions for finding the product on Amazon through keyword searches. The reviewer then purchases the product on Amazon and, because they are a verified buyer, they are able to write the review. The review must be five stars, as implied by most of the descriptions for the Facebook groups that promise five-star reviews for the seller and confirmed in a conversation in which they asked an agent how the process works. It cannot include any disclosure that the review was written in exchange for a free product.¹⁴ Reviewers increasingly use AI to generate the review they post.¹⁵

Step 3The refund

Once the agent and seller have confirmed that a fake five-star review has been successfully written by the reviewer, the reviewer is refunded the cost of the product, typically via PayPal.¹⁶ Some 15% of products in these groups come with an additional commission for reviewers.¹⁷ Again, the essential difference between this process and review incentivization sanctioned by platforms is that receiving the refund is conditional on the reviews being five stars. Sellers will only refund reviewers once there is proof of a five-star review existing.

Facebook groups for other platforms

There is one key difference between how the market works for e-commerce platforms like Amazon and review aggregators: the lack of a product to order online means the incentive for reviewers needs to change. Seemingly, from various Facebook groups for Google reviews, reviewers are paid for each review they write instead of receiving a free product. In this scenario, there is no need for the cost of the product to be refunded to buyers, since they do not actually need to make a transaction in order to qualify for writing a review on Google.

There is also evidence of ‘review swap’ deals where businesses can exchange positive reviews with each other, presumably for free. Business owners will typically post their location, requesting review swaps in similar areas—likely this is to make the reviews look as organic as possible. Business owners also sometimes indicate the number of accounts they have (and therefore the number of fake reviews they can provide).

Fake review websites

Amazon has commenced civil proceedings against the operators of two websites that it alleges sell fake reviews: Skitsolutionbd.com and Amzreview.ca.¹⁸ Looking at these two websites provides an idea of how fake review websites operate, though this channel is more opaque than the Facebook groups by nature of the venue. Both websites were still up at the time of writing.

Amazon’s suit against the operators of Skitsolutionbd.com was filed jointly with the Better Business Bureau in the Superior Court of Washington for King County in October 2025 (Case No. 25-2-29591-5 SEA). The complaint pleads, among other things, tortious interference, and alleges that the defendant, whom it describes as the Bangladesh-based operator of the website, has been selling fraudulent reviews since March 2019.¹⁹

The Amzreview.ca suit was filed in June 2025 in the same court (Case No. 25-2-18887-6 SEA) against the as-yet unidentified operators of the website. Amazon alleges that they were running a fake review scheme with a network of over 8,000 reviewers worldwide and using methods to evade detection. That suit seeks damages and injunctive relief, also on tortious interference grounds.²⁰ The allegations in both proceedings are Amazon’s and have not been tested in court.

Skitsolutionbd.com

Skitsolutionbd.com offers a suite of ‘marketing services’ for many different e-commerce platforms, including Amazon. Among these services are five-star reviews offered for sale, advertised as “real, legit and authentic reviews” and a “100% safe” way to increase sales. This offering itself has several five-star reviews, purportedly from Amazon sellers who praise the fast service and sales boost. One purchased five-star review ordinarily costs USD$35, but was marked down to USD$20 at the time of visiting in November 2025. The website also offered a bulk discount for orders over USD$1000 and promised a refund guarantee for “unsuccessful delivery”. Similar positive review services were listed for Facebook, Walmart, Etsy, eBay, AliExpress and Google.

The equivalent product for Google reviews was cheaper: discounted to USD$12 from an original USD$20. However, this is still not nearly as economical as the example from the Facebook group offering fake five-star Google reviews at a starting rate of $2 per review.

The 89 reviews for this product were overwhelmingly positive, though it is difficult to trust their authenticity when the seller is quite literally in the business of selling reviews.

Alternatively, the website offers a takedown service for negative reviews, ordinarily priced at USD$150, but marked down to USD$100, per review removed. Among its ‘online reputation management’ services, the website sells negative reviews for a seller’s competitors, advertised as the “[b]est way to defeat [an] opponent”, and for only USD$20 each. The product even explicitly promises to reduce a competitor’s rating and number of customers.

Amzreview.ca

The second website, Amzreview.ca, is similar, though it uses a Canadian (.ca) domain and is specific to Amazon. It offers five-star Amazon reviews in bulk, with a starting price of $15 per review, and claims to employ 4,500 Canadian reviewers. It clarifies that this price does not include the price of the product, which presumably goes towards refunding the reviewer. This suggests the process resembles the one used within the Facebook groups. For each of its packages, the website promises reviews containing both text and images from verified purchasers, with replacement guarantees in case Amazon takes down the review.

Amzreview.ca describes its method as “risk free” and explicitly references Amazon’s sophisticated fake review detection algorithm. To avoid raising alarm bells, the website claims that it screens its reviewers thoroughly, including checking their review history and various demographic factors. Presumably, this screening process is intended to weed out reviewers that might present more suspicion for Amazon’s detection strategies.

Why do firms buy fake reviews?

While the motivation may seem obvious, it is worth briefly exploring the incentives for businesses to purchase fake reviews and the systems that shape those incentives. For businesses, the logic is simple: because high ratings and rankings have become a deciding factor in consumers’ purchasing decisions, fake positive reviews have a substantial potential to impact sales. Indeed, firms who purchase fake reviews on Amazon see a short-term boost in their weekly sales.²¹ Many of the Facebook groups and both websites even explicitly attract sellers or businesses with the promise of increased rankings and sales.

He, Hollenbeck and Proserpio’s work on the topic suggests that if a fake review is able to generate as little as one organic sale, it is worth the price for most of the firms purchasing them.²² Beyond that, when fake review websites guarantee to replace any reviews that are removed, it de-risks the purchase and makes fake reviews even more worthwhile. There is a powerful incentive to purchase fake reviews, especially when it is so easy for sellers and businesses to get away with it.

The benefit of fake positive reviews is compounded when reviews factor not only into consumer purchasing decisions but into how platforms display products and results from keyword searches. While these algorithms are largely unknown, it is understood that a large volume of positive reviews and high ratings are critical factors. He, Hollenbeck and Proserpio confirm that “products recruiting fake reviews improve their search position substantially” and that the impact is long-lasting.²³ Reviews and rankings also often influence how platforms automatically present search results or award certain badges or labels to products, like “highly rated” or “best seller” labels that can further promote visibility, thereby creating an even stronger incentive for purchasing fake reviews.

Because positive reviews and a high rating are so powerful, not only as a mark of quality, but also to enable discoverability on platforms with huge volumes of competitors, the incentives for fake reviews are immense. The fact that e-commerce firms are largely at the mercy of the platforms when it comes to whether or not their products are seen by potential buyers makes fake reviews all the more tempting.

For physical businesses, reviews may be slightly less essential for swaying consumer choice. The discoverability of a physical business is not entirely dependent on how a platform like Google Maps displays search results. Consumers might stumble across a business’ physical presence without first consulting its virtual one. Still, the same incentives for purchasing fake reviews persist, and are likely to intensify as checking online reviews becomes a default step for more and more consumers.

Beyond the incentives, fake reviews are incredibly easy to acquire. In an experiment using a fake Facebook business profile, an investigation by the UK-based consumer advocacy group Which? found that hundreds of fake reviews can very easily be accumulated within a week.²⁴ Posing as various businesses, Which? also found that review brokers make many assurances that the process is completely safe and that platforms rarely catch fake reviews.²⁵ Even then, the consequences for getting caught purchasing or writing fake reviews are generally insubstantial. Powerful incentives for purchasing them, combined with their accessibility and relatively low risk, make fake reviews incredibly attractive.

Harms of review brokerage

Harms to consumers

Unsurprisingly, the statistics about the power of online reviews have troubling implications for the potential of fake reviews to sway consumer choice. Platforms also make it incredibly easy for reviews to have an influence on the consumer by awarding various ‘highly rated’ badges on the basis of reviews or ratings, or providing filters to sort products above a certain rating threshold. A behavioural study from Which? confirms that fake reviews are indeed highly effective at influencing consumer behaviour.²⁶ Fake reviews encourage consumers to purchase lower-quality products or services and decrease trust in reviews more broadly. A working paper by researchers Gandhi, Hollenbeck and Li characterizes these impacts as misinformation, where consumers are deceived about the quality of a product, and mistrust, where overall consumer trust in reviews declines.²⁷

For e-commerce products, fake reviews cause consumers to inadvertently buy a product of much lower quality than the fake, positive reviews would have led them to believe. In other words, fake reviews are a form of misinformation that leads consumers to vastly overestimate the true quality of a product.²⁸ Crockett’s investigation anecdotally confirms this fact: when he plugged the charger he ordered from a seller advertising it in a fake review Facebook group into his phone, it immediately snapped.²⁹

The harm is principally economic: consumers waste money on a product that does not live up to expectations, or may even be defective. When fake reviews mask the true quality, and therefore the value for the price of a product, they also make it difficult for consumers to comparison-shop effectively. Consumers are likely to miss out on products that would have offered them much better quality for the same price, or a slightly higher price. Fake reviews also raise the prices of the low-quality products they promote by requiring sellers to offset the price of the fake reviews themselves,³⁰ and may even enable the sellers to further raise their prices to match their falsely inflated ratings.³¹

Quantifying the harms of fake reviews is more difficult than describing them. Estimates on the prevalence of fake reviews vary widely. One report from the UK government found that 11% to 15% of reviews for 3 common e-commerce products were fake,³² while a more extreme statistic suggests that up to 43% of reviews for Amazon’s bestsellers are “unreliable”.³³ Tripadvisor’s own Transparency Report suggests that 8% of the reviews submitted to the platform in 2024 were fake, though these are just the ones successfully identified.³⁴

For some products the risks of misinformation and deception are far greater. Many counterfeit and defective products are widely available on Amazon and potentially dangerous, like faulty oven mitts, electronics with fake certifications,³⁶ or even counterfeit car seats that do not hold up in a crash.³⁷ The harms of such products are only compounded by fake reviews that obfuscate their true quality, and mask the warnings contained in legitimate reviews.

It is worth acknowledging that most e-commerce platforms offer fairly lenient return policies, which helps address one of the potential harms of fake reviews. If a product does not live up to expectations, consumers can simply return it and get their money back. But in some cases, the low quality of a product might not become evident until after a few uses, once the return window has passed, or after harm has come to the consumer. In any case, considering the problem of fake reviews to be solved by return policies places an undue burden on consumers and maintains the erosion of trust in the online review ecosystem.

All fake reviews present the same general risk of deception, but there is one type of business for which the harms of fake reviews are inarguably the most pronounced: healthcare. In the UK, a warning was issued to consumers after a BBC investigation revealed that some medical clinics were using fake reviews to boost their Google profiles.³⁸

Former federal investigator Kay Dean, who runs a YouTube channel called ‘Fake Review Watch,’ has documented numerous instances in which, on her analysis, medical clinics in North America appear to have received fake reviews, including a Toronto dental office³⁹ and a Washington, D.C. laser eye surgery clinic.⁴⁰ It is not difficult to imagine other businesses where fake reviews present greater risks due to the sensitivity of the services they deliver: say law firms, medical spas or psychologists⁴¹—all categories in which Dean has reported evidence of the use of fake reviews.

Where a regulated professional chooses to purchase fake reviews, it is legitimate to ask whether that willingness to mislead the public is confined to marketing. At a minimum, fake reviews deprive patients and clients of reliable information at the very moment they are choosing a provider, and may steer them toward a provider they would not otherwise have chosen, with consequences that can range from a poor outcome to serious harm. And unlike e-commerce products, medical procedures cannot simply be returned if they do not live up to the expectations set by fake reviews. This type of fake review is no longer a question of deceptive marketing, but one of serious public health and safety, and necessitates a dedicated response.

Harms to honest sellers

The impacts of fake reviews are also pronounced for the honest sellers who choose to compete fairly and forgo purchasing them. Firms who are directly competing with purchasers of fake reviews are unfairly disadvantaged, and all firms are indirectly harmed by decreased trust in reviews writ large.

It may be tempting to categorize fake reviews as a form of anti-competitive conduct by the firms who purchase them, but Sandeep Vaheesan’s framework of law-breaking as a method of unfair competition is more useful.⁴² Vaheesan posits that firms gain a “critical and illegitimate advantage over competitors” through law-breaking.⁴³ That advantage can be financial or reputational, and enables them to steal sales and market share from their law-following competitors. Applied here, firms that purchase fake reviews are competing by breaking the rules—both platform policies and, in Canada, the deceptive marketing provisions of the Competition Act—to gain an advantage over the firms that abide by them.

By decreasing consumers’ trust in reviews more broadly, fake reviews harm all firms. Consumers will be less likely to trust reviews and ratings that are genuinely positive for honest firms, creating another barrier to fair competition.⁴⁵ There is also a chance that decreased trust in reviews may require that honest sellers price their products or services more competitively in order to draw consumers in, since they can no longer rely on their high ratings to do so⁴⁶. Thus, fake reviews provide a clear competitive advantage to the sellers that use them and disadvantage the honest sellers who do not.

When so many of their competitors are cheating and getting away with it, honest firms may feel they have no choice but to cheat as well in order to neutralize the unfair advantage earned by their competitors. This domino effect compounds the harmful impacts of fake reviews on consumers and makes clear why proper enforcement against fake reviews is essential. When a firm sees their law-breaking competitor fairly punished, it makes it less likely that they will engage in the law-breaking themselves.

Harms to platforms

The impact of fake reviews on consumer trust is also felt by the platforms that host them. Because fake reviews deceive and harm consumers, they have potential repercussions for the reputation of platforms.⁴⁷ By factoring reviews and ratings into how they present search results or award certain badges, platforms inadvertently endorse products or businesses with high numbers of fake reviews. The platform’s endorsement of what the consumer then realizes is a low-quality product or service will reflect poorly on its reputation and trustworthiness.

Potential legal liability is another harm vector for platforms. Given that fake reviews are prohibited under consumer protection or competition law in many jurisdictions, platforms with high volumes of fake reviews may be held legally responsible in some circumstances. Regulators in other jurisdictions have already taken enforcement action against platforms, and Canada’s Competition Bureau is investigating Amazon’s marketing practices relating to reviews and ratings under the Competition Act’s deceptive marketing provisions. Where fake reviews have more serious potential consequences, as in the case of medical clinic reviews, the legal liability or repercussions for platforms may be higher.

Fake reviews also create a burden of enforcement, though not an undue one, for platforms who must implement numerous detection mechanisms and removal strategies. For platforms like Amazon with lenient return policies, high concentrations of fake reviews might also mean they are processing greater volumes of returns as consumers send back products that do not live up to expectations. With these clear costs in mind, it is worth considering the incentive structures and platform policies that have nonetheless allowed for the proliferation of fake reviews.

What is already being done?

Though we may be at a high-tide moment for the prevalence of fake reviews, there are already efforts in motion to address this consumer protection crisis. A number of actors, including the platforms themselves, around the world have taken or proposed steps to rid the internet of fake reviews. Still, these efforts mark only the starting point, and Canada must do more.

By the platforms

Soliciting fake reviews is not permitted on e-commerce marketplaces. Amazon states in its ‘Anti-Manipulation Policy for Customer Reviews’ that “[a]ny attempt to manipulate reviews, including by directly or indirectly contributing false, misleading or inauthentic content, is strictly prohibited”.⁴⁸ It recently reiterated that it has “zero tolerance for fake reviews”.⁴⁹ eBay’s ‘Feedback Policy’ and Walmart’s ‘Ratings & Reviews Policy’ similarly ban fake reviews.⁵⁰ Review aggregating platforms also ban fake reviews. On Google Maps, any form of rating manipulation is prohibited, including the solicitation of content that does not reflect a genuine opinion.⁵¹ There are equivalent bans on soliciting reviews in Tripadvisor’s ‘Content Integrity Policy’ and Yelp’s ‘Content Guidelines’.⁵²

Like many of these platforms, Amazon uses a variety of methods, from AI-based detection tools to human investigators, to detect and remove fake reviews.⁵³ Amazon has gone the furthest in its enforcement of its anti-review brokerage policy through legal recourse.

Its two lawsuits against the two fake review websites examined above are only the most recent examples; Amazon has a long history of legal action against Facebook group administrators or fake review brokers.⁵⁴ According to an Amazon press release, it also previously obtained judgment against the operators of over 75 fake review websites and seller accounts, and it reports having deactivated over 150 such websites as of July 2025.⁵⁵ Amazon also often reports the problematic Facebook groups to Meta. In a press release from 2022, it claims to have reported over 10,000 groups, which Meta reportedly took down more than half of.⁵⁶

Other platforms have taken similar actions, including Trustpilot, which successfully sued two businesses that purchased and submitted fake reviews to its platform and obtained court orders to ban them from doing so.⁵⁷ One of those businesses, particularly of note, was a dental practice which, according to Trustpilot, had received 1,868 reviews that Trustpilot determined to be fake.⁵⁸ In 2024, Trustpilot reported removing 4.5 million fake reviews (7.4% of the total number of reviews submitted), 90% of which were removed automatically by its automated detection tools.⁵⁹ Tripadvisor reports catching, blocking or removing 2.7 million fraudulent reviews in 2024 (a little over 8% of the total number of reviews they processed), though only 4.8% of those are what it terms “paid reviews”.⁶⁰

Evidently, the platforms all maintain policies that prohibit fake reviews, and enforce them to a certain extent. The question is whether those policies and enforcement actions are sufficient given the scale and persistence of the problem.

In Canada

Thankfully, most forms of review fraud fall within the deceptive marketing provisions of Canada’s Competition Act. While they do not explicitly include fake reviews, those provisions in section 74.01 of the Competition Act state:

A person engages in reviewable conduct who, for the purpose of promoting, directly or indirectly, the supply or use of a product or for the purpose of promoting, directly or indirectly, any business interest, by any means whatever, // (a) makes a representation to the public that is false or misleading in a material respect.⁶¹

Fake reviews fit into this framework as a false representation under the presumption that reviews are genuine expressions of the writer’s opinion and intended to promote a product or service. Two previous Competition Bureau investigations confirm the application of these provisions against various forms of fake reviews: an investigation against Bell, concluding in 2015, and one against a company called AmpMe, in 2023.

Bell was investigated by the Competition Bureau for astroturfing by encouraging its employees to post positive reviews about an app it was launching, MyBell Mobile, in app stores.⁶² The Bureau reached a consent agreement with Bell in 2015, which saw the company committing to a corporate compliance program and paying an administrative monetary penalty of $1,250,000.⁶³ A consent agreement is registered with the Competition Tribunal and has the force of a court order, but it reflects a negotiated resolution rather than an adjudicated finding of liability. In this case, the agreement states that the Commissioner concluded that Bell’s actions met the elements of section 74.01 of the Competition Act.

More recently, the Competition Bureau investigated a Montreal-based company, AmpMe, which it concluded had purchased positive reviews from third parties for its mobile application.⁶⁴ The Bureau stated that purchased reviews “created a false or misleading general impression among the public” and “influenced the application’s ranking and overall rating”. The Commissioner reached a consent agreement with the company in December 2023, similar to the Bell agreement, under which AmpMe agreed to pay an administrative monetary penalty without admitting liability.⁶⁵ The Bureau’s position further clarifies that purchased reviews can be considered false or misleading simply on the basis of not being from genuine consumers.

While the above cases showed that the law applies to companies purchasing or producing fake reviews themselves, whether this liability under the Competition Act extends to platforms remains unclear. In conducting a deceptive marketing investigation of Amazon itself, the Competition Bureau is testing whether the e-commerce giant could be held liable for the fake reviews on its platform. This investigation began in late 2021, amidst rising consumer concerns over fake reviews.⁶⁶

In June 2024, the Federal Court of Canada ordered Amazon to turn over records relevant to its investigation to the Bureau.⁶⁷ A subsequent application by the Commissioner for additional transaction data was refused by the Federal Court, and that refusal was upheld by the Federal Court of Appeal in March 2026.⁶⁸ The Bureau has stated that the investigation remains ongoing. No finding of any contravention has been made against Amazon, and Amazon has not been found to have acted unlawfully.

According to Federal Court hearing transcripts, the investigation seeks to understand whether Amazon “has a business interest in turning a blind eye to Fake Reviews,” and “whether, given the economic consensus, Amazon has a financial interest to make or permit reviews.”⁶⁹ The investigation is also concerned with how claims made by Amazon “may be influenced by reviews and ratings, a factor that could affect how products are ranked and displayed on their website and mobile app.”⁷⁰ Those claims include a product’s overall star rating and badges awarded by Amazon, like the “Amazon’s Choice,” “Verified Purchase,” “Best Seller” and “Top Reviewer” badges.⁷¹

From the publicly available material, the question seemingly at the heart of the investigation is whether Amazon makes a false or misleading representation by using fake reviews in aggregating overall star ratings or in assigning badges, and whether it has a financial incentive to do so. If the Bureau’s theory were accepted, Amazon could in principle be found responsible for indirectly making a false or misleading representation available to the public. Though it is unclear at this time whether the case will find its way to Canada’s specialized competition court, the Competition Tribunal, its outcome will have important implications for the future of fake reviews on the largest e-commerce platform in Canada.

In other jurisdictions

A number of other jurisdictions have also taken action against fake reviews, including the U.S., the U.K., Italy, the E.U. and Australia. The U.K.’s Competition and Markets Authority (CMA) has been particularly active against fake reviews over the past few years, launching inquiries into Amazon, Facebook, eBay and Google. The investigations, now concluded, have had similar outcomes.

In 2020, eBay and Facebook agreed to better address concerns about review brokerage.⁷² The CMA also alerted Facebook’s parent company, Meta, that fake reviews were being sold on its other platform, Instagram, and it agreed to investigate the issue. In 2021, after a follow-up investigation found that updated measures were ineffective at tackling review brokerage on both Facebook and Instagram, Meta again committed to strengthening them.⁷³ The strengthened measures include suspensions or bans for users repeatedly creating Facebook groups or Instagram profiles for the purpose of review brokerage, and changes to search tools to make it more difficult to find these groups or profiles.

In January 2025, following the conclusion of the CMA’s investigation, Google committed to stricter measures for addressing fake reviews. Among these measures are prominent consumer warnings to be added to the profiles of businesses caught purchasing fake reviews and bans for reviewers frequently caught writing them.⁷⁴ Most recently, in June 2025, Amazon came to its own agreement with the CMA. Amazon agreed to strengthen its enforcement against fake reviews, including via sanctions for sellers caught purchasing (or users caught writing) fake reviews.⁷⁵ Bans are the only sanction mentioned, and only as a possibility.

Even earlier, in 2015, Australia’s Competition and Consumer Commission fined businesses for fake reviews posted on Google and YouTube,⁷⁶ and Italy’s Competition Authority fined Tripadvisor for its claim that its reviews were “true and authentic”, despite the presence of numerous fake ones.⁷⁷ This fine was subsequently annulled on appeal by the Regional Administrative Court of Lazio.⁷⁸

From a legislative standpoint, many jurisdictions go further than Canada and explicitly prohibit fake reviews. Australia has several provisions that are analogous to Canada’s deceptive marketing provisions in its 2010 Competition and Consumer Act, but one key difference is its explicit ban on fake reviews. Section 29 of the Act makes it illegal to write a false testimonial—or a fake review.⁷⁹ This provision has been successfully tried in several review fraud cases.⁸⁰

Since then, the U.K. and E.U. have also taken legislative action. The U.K.’s recently enacted Digital Markets, Competition and Consumers Act explicitly includes fake reviews as a prohibited unfair commercial practice.⁸¹ Comparably, the E.U. Directive on better enforcement and modernisation of Union consumer protection rules makes fake reviews illegal via a legislative amendment to the Unfair Commercial Practices Directive.⁸² Other jurisdictions have also taken a regulatory approach to fake reviews. Most notably, the U.S.’s Federal Trade Commission adopted a rule that prohibits the sale or purchase of fake reviews, both positive and negative.⁸³ At the time of writing, the Italian parliament is also considering a law that would require anyone writing an online review to provide verifiable ID and proof that they had visited the establishment for which they are writing the review; require that reviews are posted within 15 days of a visit; and explicitly ban review brokerage.⁸⁴ Fake reviews are already illegal in Italy but this draft law is intended to simplify enforcement.

The role and incentives of platforms

While all the platforms maintain their anti-fake review stances, the persistence of the problem despite their stated efforts to crack down on it raises legitimate questions about whether their incentives and enforcement choices allow it to continue. Might the platforms be partially responsible for creating the structures and incentives that enable review brokerage to thrive? Indeed, whether Amazon has a business interest in the persistence of fake reviews on its platform appears, from the Bureau’s court filings, to be a key question in the Competition Bureau’s ongoing investigation.

Here, it is worth taking a look at the largest and most dominant platforms in the fake review ecosystem: Amazon, Meta and Google.

Amazon

While helping to guide consumers, the badges that Amazon awards highly rated sellers and products also create incentives for purchasing fake reviews as a means of illicitly obtaining them. This is less a question of whether Amazon deliberately awards badges to sellers who purchase fake reviews, and more a question of its due diligence in making sure that it does not. By awarding badges, Amazon effectively certifies products with a mark of trustworthiness. If those products only merit badges because of fake reviews, Amazon indirectly enables fake reviews to reach and influence more consumers.

The available research suggests that Amazon’s efforts to deal with the problem of fake reviews fall well short of what its resources and capabilities would allow. He, Hollenbeck and Proserpio found that Amazon successfully deletes about half of fake reviews, but with an average lag of 100 days, meaning that sellers still benefit from the fake reviews before they are removed.⁸⁵ Even then, the 50% deletion rate is less impressive considering that deleting the reviews is often the only penalty levied.

It also suggests that Amazon is underutilizing tools in its arsenal to regulate fake reviews more strictly. He, Hollenbeck and Proserpio do not find any examples of Amazon deleting products or banning sellers as a consequence for purchasing fake reviews, nor deranking them in search results. Instead, they observe that the positive impact fake reviews have on keyword ranking for products lasts for months, even after those reviews have been deleted.⁸⁶

From the products investigated, Oak and Shafiq confirm that Amazon often deletes fake reviews, but that it only delists 20 of the 1,600 products whose sellers purchased them.⁸⁷ There is more Amazon could be doing to disincentivize purchasing fake reviews, even without augmenting its detection capacity. These findings are difficult to reconcile with Amazon’s public statements about the rigour of its enforcement.

For Cory Doctorow, the underinvestment in anti-fraud detection mechanisms for fake reviews is deliberate on Amazon’s part:

But for Amazon, all of this is fine. This is how its system works, its flywheel. Amazon makes money when you are satisfied, and it makes money when you’re furious. The costs are borne by sellers, and by you. Why would the company invest in fighting fraud under those circumstances?⁸⁸

Doctorow categorizes fake reviews as a symptom of “enshittification,” a process by which platforms extract value first from their users and then their business consumers, until everyone but the platform is worse off. Through this process, he argues, Amazon has extracted so much value from the good, honest sellers that it is now oversaturated with the bad actors purchasing fake reviews.⁸⁹

A more troubling hypothesis is that Amazon benefits, at least in the short term, from fake reviews because they boost sales and rankings, and therefore has a weaker incentive to eliminate them.⁹⁰ Yet there is no evidence that Amazon deliberately under-enforces its policies for this reason, and Amazon has consistently stated that it invests heavily in detecting and removing fake reviews.

Amazon suggests that, despite its own best efforts to crack down on fake reviews, the problem persists due to activity beyond its reach on social media platforms. Amazon attempts to shift some accountability towards social media companies, urging them to invest adequately in enforcement and detection in order to address the problem.⁹¹

Meta

As for how these reviewers become involved in the practice, Meta’s platform Facebook holds a degree of responsibility. Of the reviewers Oak and Shafiq interviewed, 75% reported being introduced to the fake review market through targeted advertisements on Facebook. These reviewers reported that Facebook’s advertising and recommendation systems surfaced fake review recruitment content to them, which suggests that those systems are capable of identifying users whose activity indicates an interest in such opportunities. Some reviewers stumbled upon the content simply by chance, without first searching for it.⁹²

This finding suggests responsibility on Facebook’s part on two counts: for algorithmically prioritizing content related to fake reviews to users and allowing fake review brokers to purchase advertisements. The second count is more serious for Meta, since these advertisements promote a practice that is contrary to Meta’s own policies and to consumer protection law.

But Meta earns advertising revenue from such advertisements just as it does from legitimate ones. Indeed, internal documents from Meta reportedly projected that roughly 10% of the company’s 2024 revenue would come from advertisements for scams and banned goods—though Meta has characterized this figure as rough and overinclusive.⁹³ This revenue distorts the incentives for Meta to completely shut down the fake review operations on its platforms, while the concentration of the online advertising market allows the biggest players to deliver enforcement against fraud that appears to be inadequate.⁹⁴

Much like Amazon, Facebook’s seemingly lacklustre approach to enforcing its policies against fake review groups raises serious questions. Facebook’s main strategy is periodic removal of the groups, though they tend to reemerge quickly.⁹⁵ It is unclear whether or not Facebook bans users associated with the groups, though that would be an appropriate consequence, especially for repeat offenders. Indeed, Facebook pledged to suspend or ban users who repeatedly create fake review groups in its 2021 commitments to the CMA, though there was no expectation that these changes would be made outside of the UK.⁹⁶

Facebook has also implemented warnings on searches for keywords associated with review brokerage—likely due to its commitment to the CMA to make it more difficult to find fake review groups with its search tools⁹⁷—but those have not been applied universally. A Which? investigation found that Facebook now prompts users who search for groups called ‘AMZ reviewers’ with a warning that the term is associated with fraudulent behaviour, but not for the spelled-out ‘Amazon reviewers’ version—a clear oversight in enforcement.⁹⁸ Even then, a warning message does not seem like a sufficient step: fake reviewers already know that they are engaging in illegal behaviour⁹⁹ and will not be dissuaded by such a message.

Interestingly, a Facebook search in January 2026 from a device in Canada for “amazon review” yielded no search results, with no warning message, but changing the search slightly to “amz reviews” yielded multiple groups whose names and descriptions indicate that they exist to recruit Amazon reviewers, targeted to users in Canada and other countries. Searches for “google reviews” quickly yielded similar results. Today it remains easy to find and join Facebook groups for the purpose of buying or soliciting, selling and writing fake reviews for numerous different countries and numerous different review-hosting platforms.

Google

Like Amazon’s, the volume of businesses on Google Maps creates a powerful incentive for purchasing fake reviews. Google’s “Local Guide” system awards points for each review written, eventually translating into different levels and badges.¹⁰⁰ Similarly to Amazon, Google creates an unofficial certification system for reviewers, where reviewers with higher local guide levels are ostensibly more trustworthy.

Unfortunately, it can also falsely certify fake reviewers as trustworthy simply based on the volume of reviews they write. Indeed, there is evidence of these reviewers promoting their local guide status as a selling point, and consumer advocate Kay Dean has found instances of local guides writing fake reviews.¹⁰¹

These platform design elements do not deliberately incite fake reviews, and often are valuable to consumers, but they raise the due diligence expectations for a platform like Google.

The process is straightforward, and one that Google should theoretically be able to replicate on a much larger scale with its advanced engineering capabilities. However, in some cases, it has been Dean’s own investigative process and findings that spurred further enforcement action by Google.¹⁰⁴

Google does not receive a commission from the sales of the businesses that it directs consumers to, nor does it collect profits from fake review ads like Meta. Listing a business on Google Maps is free,¹⁰⁵ which means Google does not have a direct financial incentive to leave up businesses that purchase fake reviews instead of suspending or barring them. Google’s incentive is to collect data on these businesses and in turn leverage that data to attract users to its platform. Whether or not as a result of this indirect relationship, the outcome appears to be that Google’s incentive to invest in proper enforcement against fake reviews is weaker than it could be.

Challenges of dealing with fake reviews

The role and incentives of platforms present one challenge to dealing with fake reviews. But there are several reasons why fake reviews are such a persistent issue across platforms and across jurisdictions.

Assigning legal liability

There is little doubt that fake reviews can constitute reviewable conduct under the deceptive marketing provisions of the Competition Act—it is the assignment of liability that is challenging. More specifically, subsection 74.01(1) specifies that the person making the representation available to the public can do so “directly or indirectly”, which suggests that all parties, including sellers purchasing reviews, the reviewers, Amazon and Facebook, may all be liable. A press statement from the Competition Bureau interprets these provisions similarly: “anyone who writes or permits writing reviews that give a false or misleading impression to consumers could be liable”.¹⁰⁶

Reviewers, review brokers and third-party sellers or businesses may be liable for directly making a false representation to the public by writing, brokering or paying for reviews, respectively. By displaying fake reviews, e-commerce platforms and review aggregators arguably make a false representation available indirectly. While the outcome is still uncertain, this view underpins the Bureau’s ongoing investigation into Amazon. By facilitating the review brokerage operation, platforms like Facebook indirectly allow a false representation to be made to the public.

The CMA’s investigation into Facebook suggests a similar position. The CMA, while clarifying that it does not allege Facebook intentionally allows fake reviews to be organized via its platform, still found “troubling evidence that there is a thriving marketplace for fake and misleading online reviews.”¹⁰⁷ It was following this and subsequent investigations that Facebook made several commitments to the CMA to take further actions against fake review groups.¹⁰⁸ The Competition Bureau has previously confirmed that firms purchasing fake reviews could be held liable through its agreement with AmpMe, though this liability was never established at the Tribunal.¹⁰⁹ There are also notable differences between the AmpMe case and the review brokerage operations for large platforms. For AmpMe, it was a single firm purchasing fake reviews. If the Bureau were to go after firms purchasing fake reviews, even just on Amazon, it would involve an unwieldy number of individual firms, with separate investigations for each. These investigations would be highly resource-intensive and fail to address the problem on a platform-wide level.

The fact that many of these sellers are not based in Canada presents another challenge, since it would be difficult to enforce without adequate Know Your Customer (KYC) data. Targeting individual reviewers presents similar challenges related to legal jurisdiction and scale—effectively an endless whack-a-mole game as new reviewers pop up to replace ones that have been banned. Comparably, action against the platforms requires only a single investigation for each and, hopefully, can effect systemic change.

Limits of the legal framework and process

The Competition Bureau’s investigation into Amazon is an important first step towards addressing review brokerage, but it cannot be relied on alone. For one, the case of Amazon may not fit neatly into the legal test of the Competition Act, ostensibly legislation focused on competition rather than consumer protection. Whatever the outcome, there is also an extended timeline for any resolution to the matter. The investigation into Amazon has been underway since November 2021¹¹⁰—over four years in, there is no way of anticipating how much longer it may take. Using Cineplex as a comparable case, if the investigation were to proceed to the Competition Tribunal, it would be at least another year before a decision was reached, putting the timeline for resolution beyond the five-year mark.¹¹¹

Even a favourable outcome would not necessarily alleviate the problem of review brokerage. The Competition Bureau has indicated particular interest in how Amazon makes representations—assigning “helpful votes, Amazon’s Choice badge, Verified Purchase badge, Best Seller badge, Top Reviewer badge and ranking, and Top reviews from Canada”—and how it displays search results on the basis of product reviews.¹¹² It is possible that enforcement action against Amazon may only seek to restrict the basis on which Amazon can make such representations, which would not directly target the existence of fake reviews. Say, for example, Amazon could no longer use reviews and star ratings to award certain distinctions. Such an outcome would only address the issue that distinctions were being awarded unfairly and therefore deceiving consumers, but not the issue that fake reviews themselves can deceive consumers.

But a successful win at the Tribunal would establish the precedent that platforms can be held liable for fake reviews purchased by the third parties that they host. This would simplify future litigation and encourage better practices across the industry. Even then, individual cases would still need to be brought against individual platforms. This effect would be muted if the Bureau and Amazon were to settle and reach a consent agreement, with no firm precedent set.

Detection of fake reviews

Review brokers always seem to be one step ahead of the platforms and find measures to circumvent new detection measures. As studies have found, these actors “are continuously improving and perfecting their manipulation strategies so that findings that were true only a few years ago, or strategies that could have worked in the past to eliminate fake reviews, might be outdated today.”¹¹³

Take the Facebook-Amazon example, where it was found that review brokers employ numerous anti-detection measures. On Facebook, brokers often deliberately misspell keywords such as ‘Amazon’, ‘refund’ or ‘review’ in their posts—often by swapping or omitting a single letter—to avoid automatically being flagged by Facebook. Brokers will also post their content through screenshots of text, rather than actual text to make it difficult for automated systems to detect keywords.¹¹⁴ Even when Facebook does detect and shut down these groups, they tend to reemerge under different names.¹¹⁵ The brokers will also sometimes proactively share backup contact information with reviewers to facilitate the creation of these new groups.¹¹⁶

In the purchasing process, brokers provide reviewers with a number of strategies to make the purchase look as organic as possible. Brokers never provide reviewers with the direct product link to purchase the product, instead giving instructions to the reviewer on how to find it, since Amazon can easily detect purchases via product link and flag any subsequent reviews as suspicious.¹¹⁷ For similar reasons, brokers encourage reviewers to pretend to search through results before ‘finding’ the correct product and to wait at least 10 days before posting a review.¹¹⁸ These are also just the tactics that have been well observed: it is likely that review brokers and reviewers employ others as well.

The sophistication of review brokerage’s anti-detection strategies is well demonstrated by Amazon and Facebook’s continual failure to successfully address the problem.

Detection of fake reviews on review aggregating platforms presents different challenges. Unlike marketplaces, review aggregators do not mediate the transaction between the seller and the consumer; instead transactions happen externally. For example, one might check Google reviews before visiting a new restaurant, but the meal would not be purchased through Google. This degree of separation means that the platform has less visibility into transactions, and therefore less information by which to legitimize reviews. For review brokers, it saves the work of having to make a transaction look authentic in the first place and makes detection even more challenging.

Review aggregators, however, can exploit a feature that e-commerce platforms cannot in detecting fake reviews. While Amazon’s products can reach consumers globally, there is a certain point where the geographical location of reviewers should cause suspicion for review aggregators. It is not plausible that the same set of reviewers scattered across the globe would all review the same set of equally spread-out businesses.

The limits of consumer awareness

Consumer awareness is sometimes proposed as a solution to fake reviews. The premise is that consumers that can better detect fake reviews will be less inclined to purchase from firms using them, which therefore makes fake reviews less effective at incentivizing organic sales. However, there is good reason to reject that premise given studies have shown that consumers cannot successfully detect fake reviews.

Not only might consumer awareness be an ineffective tool at addressing fake reviews, it may also be entirely counterproductive. One study reports that upon being informed about the existence of fake reviews, consumers actually became more suspicious of all reviews, despite not being any better at detecting them.¹²¹ Review brokerage thrives on the basis of incredibly realistic fake reviews that are expressly made difficult to detect. Increased suspicion of all reviews is potentially damaging, since if consumers perceive a review as fake when it is actually genuine, there are negative repercussions for firms with genuine reviews.¹²² Accordingly, there is a real concern that strategies to increase consumer awareness may inadvertently negatively impact all firms through misplaced distrust in all reviews.

Consumer awareness campaigns also place an undue burden on consumers for the detection of fake reviews. It should not be a consumer’s responsibility to detect the fake reviews that even the largest digital platforms like Amazon and Google, with all the many tools and resources at their disposal, struggle to remove.

Dealing with fake reviews

To improve on the current state and deliver better outcomes for consumers, there are several mechanisms that can curb the problem of review brokerage. Both platforms and regulators have a role to play as part of a comprehensive three-pronged strategy for tackling fake reviews.

The role of regulators is to hold the platforms that facilitate review brokerage accountable for punishing the actors involved. While the rationale is the same, different requirements are needed for review-hosting platforms than for social media platforms.

• For review-hosting platforms, requirements should be focused on increasing the cost of purchasing or writing a fake review through harsher disciplinary action. This could involve mechanisms like the ‘name-and-shame’ model. Disciplinary action should also be proportionate to the harms, which means harsher punishments for self-regulated professionals purchasing fake reviews (Pillar 1).
• For social media platforms, requirements should centre on better enforcement of policies against illegal activity and due diligence for ad customers (Pillar 2).

Simultaneously, platforms should explore alternative review systems to address some of the underlying incentives for purchasing fake reviews, while pursuing robust enforcement of their policies against fake reviews (Pillar 3).

Increased disciplinary action

For review-hosting platforms, the primary aim is to increase the severity of penalties levied on actors involved in review brokerage. The evidence suggests that while platforms like Amazon and Google do successfully detect a substantial portion of fraudulent review activity, they underutilize a number of tools at their disposal. Currently, platforms seem to rely heavily on the deletion of fake reviews as a sole penalty, which has evidently failed to provide enough of a disincentive for firms to continue purchasing them. With harsher punishments for firms caught purchasing fake reviews, the opportunity cost of a fake review increases, with the potential to change the underlying incentives for participants.

Anti-fraud legislation could prescribe a number of different appropriate penalties for platforms to employ, including suspensions, lifetime bans for repeat offenders, public consumer warnings (‘name-and-shame’), fines, or search ranking deprioritization. In particular, platforms should be required to reverse any positive impact that fake reviews caused on a product’s visibility in search results, so the firm at the very least does not continue to benefit from fake reviews once they have been detected and removed.¹²⁴

The legislation could include provisions about adequate detection of fraudulent activity on platforms, with penalties for non-compliance if certain targets are not met. Stricter requirements for due diligence could apply for products and firms that a platform endorses through its own badges, labels or otherwise promotes. Platforms should also be required to monitor banned or suspended actors to ensure they cannot easily create new accounts. Still, adequate detection of fake reviews means little if the actors involved are not being adequately punished.

Another component should be reporting obligations for platforms: the information about actors involved in the fake review networks generated through increased detection and enforcement activity would be compiled into a bad actors registry, shared across review-hosting platforms. Often, these actors are not operating on only a single platform, so the registry could support efforts to streamline detection across platforms. Such intelligence sharing enables platforms and regulators to better collaborate in tackling online fraud.¹²⁵

Name-and-shame

The ‘name-and-shame’ model is a disciplinary mechanism by which consumer warnings are prominently displayed on the pages of firms caught purchasing fake reviews or reviewers caught writing them. It was included as part of Google’s commitments to the CMA,¹²⁶ and though its effectiveness has not yet been tested there, it is an example worth exploring.

Consumers are less likely to purchase from firms with such warnings, which sways the cost-benefit analysis for firms purchasing fake reviews in the first place.¹²⁷ The implications are similar for reviewers: if a reviewer’s profile is branded with a clear warning for consumers, any review they write will immediately raise suspicion. Transparency-based mechanisms also increase consumer trust more broadly by demonstrating that a platform takes fraud seriously—more than simply deleting fraudulent activity does.¹²⁸

Some platforms already use name-and-shame mechanisms. For example, Yelp uses both Compensated Activity Alerts, for businesses Yelp has found to have offered compensation for reviews, and Suspicious Review Activity alerts, for businesses suspected of fraud.¹²⁹

Whether or not a name-and-shame penalty is prescribed by anti-fraud legislation, it is one that platforms should seriously consider as part of their enforcement strategy against fake reviews.

Addressing the serious harms of fake reviews in self-regulated professions

Canada has the clearest incentive to act where fake reviews present the greatest harm: namely, when fake reviews are used in self-regulated professions. When licensed and accredited professionals like dentists, psychologists or lawyers purchase fake reviews for their businesses, the harms to consumers are potentially more severe than for other fake reviews. There is also a much higher expectation of conduct from these professions, which demands harsh punishments when violated. While the consequences of a defective product can be serious, deception here represents a breach of the trust underlying the concept of self-regulation and creates the potential for serious physical and legal consequences for misled Canadians.

The bodies that regulate the professions and are responsible for licensing and accreditation, like Royal College of Dental Surgeons of Ontario¹³⁰ or the Law Society of Ontario,¹³¹ will need to be part of the solution. These bodies have the responsibility of determining whether or not a professional can be trusted by Canadians, and regulating their respective fields in the public interest. The Law Society of Ontario explicitly states that it regulates lawyers and paralegals “in the public interest by ensuring that the people of Ontario are served by lawyers and paralegals who meet high standards of learning, competence and professional conduct.”¹³²

When a professional violates the mark of trustworthiness conveyed by a licence or accreditation, it is a serious concern for these bodies. It calls into question their reputation and erodes the trust of the public they are meant to protect. Fake reviews are the very opposite of the high standards of professionalism they are tasked with maintaining.

While some discretion for disciplinary action may be left to these bodies, immediate revocation of the right to practise is the correct remedy to assertively prevent the use of fake reviews by self-regulated professionals. As for all types of fake reviews, the key is to make the risks of purchasing them outweigh the benefits. For these professionals, the potential profit or reputation boost achieved from fake reviews is far outweighed by the potential loss of livelihood and reputational damage of a licence suspension.

To empower licensing and accreditation bodies to make such decisions through a proper investigation, they need access to information. Even where fake reviews are suspected, it is difficult to access adequate proof without the information at the disposal of the platform hosting the reviews.

Therefore, platforms should have an obligation to report any documented instances of regulated or accredited professionals in Canada purchasing fake reviews to the respective regulatory body. Ideally, this obligation would be achieved under the anti-fraud legislation, and then could feed into the information registry.

This obligation would likely be felt most acutely by Google Maps, where there are several examples of dentists, psychologists and lawyers allegedly purchasing fake reviews in Canada. Yet when a platform functions partly as a tool to connect people with these professionals and reviews effectively provide an informal verification service, that platform must have some responsibility to its users.

Pillar 2 Requirements for social media platforms

The social media channels supporting the fake review networks must be addressed as part of a comprehensive and robust strategy against review brokerage. Meta is the primary and obvious target given the role its platforms play in hosting, and through advertising and amplifying, review brokerage activity.

On platforms like Facebook, identifying the source of the fake reviews is incredibly straightforward, intentionally so to drive reviewer and business traffic. Therefore, detection of fake review activity on social media is often relatively easier than on review-hosting platforms, where the actors have evolved sophisticated anti-detection techniques. Limiting the volume of fake reviews that can be successfully brokered by making it more challenging for actors to organize will also reduce the enforcement burden down the line.

The CMA’s multiple investigations of Facebook highlight the importance of considering where fake reviews are sourced, but also suggest an opportunity for Canada’s Competition Bureau. Under similar logic as Amazon, the Bureau could launch a parallel investigation into whether Facebook has a business interest in letting fake review activity continue on its platform and whether it could be liable for making false representations available under section 74.01.

Taking a more systemic approach, stricter requirements could be imposed on social media platforms via the comprehensive anti-fraud legislation. These requirements should include bans or suspensions for accounts associated with review brokerage, and bans on keyword searches and misspelled variations of these keywords. For example, the fact that searches on Facebook for “Amz reviews” still return groups that, by their own descriptions, exist to recruit paid reviewers seems like an evident gap in enforcement.

“Know-your-customer” rules should also be imposed to address advertisements associated with review brokerage. These rules require an entity to verify or even validate the identity of a customer, and, as CAMP has previously argued, could be applied to digital advertisement publishers as a proactive approach to ad fraud.¹³³ In the context of fake reviews, the “know-your-customer” principle would require Meta to deny any advertisements that promote review brokerage in its verification process, before it even runs the ads. Tackling these scam ads hamstrings the ability of review agents to lure potential reviewers into their groups, helping cut down the volume of reviewers involved in the first place.

Actors may ultimately adapt to other channels to organize themselves—especially given the high degree of resilience they have so far displayed—but tackling social media platforms enhances the robustness of the strategy to address fake reviews. Considering only review-hosting platforms, or only social media platforms for that matter, would neglect several opportunities for intervention in the lifecycle of a fake review.

Pillar 3 Alternative review structures for platforms

While platforms would ideally adopt many of the requirements presented above in an effort to better enforce their own policies against fake reviews, they also ought to fundamentally reconsider how review systems are designed.

Taking the time to write genuine reviews for products and businesses is a fundamentally generous act, especially as consumers are growing increasingly fatigued by demands for feedback.¹³⁴ In an ideal world, reviews operate as a sort of pay-it-forward model: a consumer writes reviews for the products they purchase and can depend on reviews from other legitimate consumers when they make their next purchase. Unfortunately, the generosity of this crowd-sourcing model has been co-opted by bad actors.

Legitimate review incentivization strategies, which provide free or discounted products and services in exchange for honest reviews, are one way to compensate reviewers for the time they spend writing reviews. Review incentivization also supports the interests of firms by allowing them to access a high volume of reviews, especially as they are just starting up. The necessity of reviews for visibility in a crowded online marketplace creates a barrier to entry for firms looking to compete on the basis of good-quality products. A legitimate channel for accessing reviews gives them a chance to answer that need without being tempted by fake reviews. However, for firms that use fake reviews to mask the true low quality of a product, review incentivization will not do much.

Many platforms like Amazon and Yelp already have review incentivization strategies in place, so here it would be a question of expanding their scope and ensuring that they are broadly accessible. For review incentivization strategies to be successful, the reviews must also be trusted by consumers. Non-negotiably, there must never be any expectation that a review is positive within review incentivization programs and it must always be transparently flagged as an incentivized review.

Amazon’s guidelines actually previously allowed sellers to offer free or discounted products in exchange for honest feedback. However, because those reviews were often biased in favour of the product and then became widely distrusted by consumers, Amazon ultimately changed the guidelines to only allow review incentivization through the official Vine Program.¹³⁵ Part of the bias may have been subconscious: a reviewer receives a product for free or heavily discounted, and therefore automatically has a more favourable opinion of the seller, or is less critical in assessing value for money. Alternatively, sellers might have been deliberately searching out reviewers who were less critical, and reviewers might have deliberately inflated their ratings to continue being selected for such opportunities.¹³⁶

Either way, it becomes clear that review incentivization programs must instruct reviewers to be entirely truthful in their opinions and as objective as possible, and should assure them that providing negative ratings or reviews will not compromise their eligibility. There must be clear guidelines and safeguards for sellers to ensure that reviewers do not feel pressured to provide positive feedback. If anything, reviewers in incentivization programs who exclusively provide positive reviews and five-star ratings must be looked on with suspicion.

Taking the recruitment of reviewers seriously can also help promote trust. Canadian Tire’s TESTED for Life program, for example, vets potential reviewers to ensure they will provide genuine and accurate reviews, and matches them with products they are most interested in.¹³⁷

Furthermore, it is essential that review incentivization programs are delivered officially and in a coordinated way by the platform. Individual sellers should not be left to select their own reviewers and organize the provision of incentives themselves, as Amazon discovered.

Ultimately, platforms should not seek to substitute proper enforcement action on fake reviews with review incentivization strategies. Such strategies are instead intended as a supplement to designing better and more trustworthy review ecosystems that recognize the essential contributions of consumers and the interests of firms.

A note on methodology and sources

Evidence in this paper was collected intermittently from January 2025 to January 2026 from Facebook groups and from two specialized review websites identified by Amazon.

I found Facebook groups through Facebook’s own search tools with keywords like “reviews” or “reviewers” and the name of the platform or retailer I was interested in (Amazon or Google). I identified groups that were designed to broker inauthentic reviews based on their descriptions, which normally contained some variation of the instruction that any review must be five stars only.

Evidence was collected from Facebook groups open to the public, with the exception of a few large private groups that quickly accepted a request to join without a vetting process. Many review agents also reached out to me directly after joining groups to offer additional products and encouraged interested reviewers to reach out with questions. Two excerpts from conversations with review agents were included in the paper. All profile names, shop links and product information have been redacted to maintain the anonymity of those involved.

References

About us

About CAMP

CAMP is a think tank dedicated to addressing the issue of monopoly in Canada. We produce research, policy, and commentary in support of a more free, fair and democratic economy.