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EU Compliance Guide

EU customer review rules for Shopify stores: the Omnibus checklist

Since 28 May 2022, every store that shows customer reviews to EU consumers must tell shoppers whether and how it checks that reviews come from real buyers or users, and must not call reviews verified unless it takes reasonable and proportionate steps to check them. Fake or commissioned reviews are banned outright. This guide explains the rules, what to publish next to your reviews, and how to handle verified badges, incentives and imported reviews on a Shopify store.

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EU law, cited in each section

Since 28 May 2022, every store that shows customer reviews to EU consumers must tell shoppers whether and how it checks that reviews come from real buyers or users, and must not call reviews verified unless it takes reasonable and proportionate steps to check them. Fake or commissioned reviews are banned outright. This guide explains the rules, what to publish next to your reviews, and how to handle verified badges, incentives and imported reviews on a Shopify store.

Where the rules come from

Directive (EU) 2019/2161, usually called the Omnibus Directive, amended the Unfair Commercial Practices Directive 2005/29/EC (UCPD). Member States had to transpose it by 28 November 2021 and apply it from 28 May 2022. Three changes concern reviews (Directive 2019/2161, Article 3):

  • A new Article 7(6) UCPD. Where a trader provides access to consumer reviews of products, information about whether and how the trader ensures that the published reviews originate from consumers who have actually used or purchased the product is material information. Leaving it out can be a misleading omission.
  • Annex I, point 23b. Stating that reviews are submitted by consumers who have actually used or purchased the product, without taking reasonable and proportionate steps to check that they originate from such consumers, is a commercial practice that is unfair in all circumstances. No case-by-case test applies.
  • Annex I, point 23c. Submitting, or commissioning another person to submit, false consumer reviews or endorsements, or misrepresenting consumer reviews or social endorsements to promote products, is also banned in all circumstances.

The Commission reads "reviews" broadly. Star ratings count too (Commission report COM(2024) 258, section 11).

The same directive added the lowest prior price rule for discounts. If you run sales into the EU, read the EU Omnibus Directive guide for Shopify and the EU pricing rules overview.

Who is affected

The duties fall on the trader that gives consumers access to the reviews. For a Shopify merchant that means you, as soon as reviews appear on product pages, in a widget or in a home page carousel, whether or not a review app collects them for you. The rules apply when you sell to consumers in the EU, whatever country your company sits in.

What "reasonable and proportionate steps" can mean

The law does not define the steps. The Commission's UCPD Guidance of December 2021 (Notice 2021/C 526/01, section 4.2.4 on user reviews) gives examples: technical means to verify that the reviewer is actually a consumer, such as an IP address check or verification by email, and clear rules for reviewers that prohibit fake and undisclosed sponsored reviews. It also says the trader should tell consumers whether all reviews are published, how reviews are sourced, how average scores are calculated and whether sponsored reviews or contractual relations influence them (EUR-Lex, 2021/C 526/01)).

The Commission's 2024 implementation report reads point 23b in two layers. A minimum every trader must meet, for example only allowing reviews from users who bought the product. On top of that, extra measures that match your business model and risks, for example tools that detect fake review patterns. A general duty to monitor everything is not required (COM(2024) 258, section 11).

For a typical Shopify store this means: collect reviews through post-purchase emails linked to an order; do not call open reviews from anyone verified; keep reviewer terms that forbid fake, paid and undisclosed sponsored reviews; and keep a record of what you check.

What you must publish near the reviews

Article 7(6) is an information duty. The practical answer is a short explanation where shoppers see the reviews, typically a note or link in the reviews widget, plus a fuller version in your terms. It should answer:

  1. How reviews are collected. Post-purchase invitation, open form, imported from a platform, or a mix.
  2. Whether only buyers can post. If yes, say how you know they bought. If no, say that anyone can post.
  3. Whether all reviews are published. Say if you hold back or delete reviews and on what grounds (spam, offensive content, off topic).
  4. Whether reviews are moderated and whether you edit them.
  5. Whether incentivised reviews are marked. If you give a discount code or a gift for a review, say so and mark those reviews.
  6. How the average is calculated and over which period, if you show a score.

The 2022 EU sweep showed how often this is missing. On 20 January 2022 the Commission and the authorities of 26 Member States, Iceland and Norway reported on 223 major websites. At least 55 percent potentially breached the UCPD and a further 18 percent raised doubts. On 144 sites, authorities could not confirm that traders did enough to ensure reviews were genuine, and 104 did not tell consumers how reviews were collected and processed (European Commission, 20 January 2022).

"Verified buyer" badges

A verified badge is a claim. Under point 23b you may only make it if you take reasonable and proportionate steps to check that the reviewer bought or used the product. On Shopify the safest basis is a review submitted through a link tied to an order in your store. A badge on an open-form or imported review is a risk. Be precise in the label: "Verified purchase in this store" says something you can prove. The Italian competition authority fined Trustpilot EUR 4 million in March 2026, partly over its "verified" label and invitation-based collection (AGCM press release PS12962).

Incentivised and imported reviews

Incentivised reviews. A discount or gift for a review is not banned in itself, but hiding the incentive misrepresents the review under point 23c. Mark each incentivised review, mention the practice in your info text and never make the reward depend on the rating.

Imported reviews.Reviews from a marketplace, a previous platform or a supplier may be shown if they are real and you say where they come from. Do not add your store's verified badge to a review you cannot trace to a purchase.

Reviews you wrote or bought. Writing your own reviews, asking staff or friends to post, or buying reviews from a broker is a point 23c practice. No disclaimer fixes it.

National enforcement examples

  • Germany. Section 5b(3) UWG transposes Article 7(6): when a trader makes consumer reviews accessible, information on whether and how it ensures that they come from consumers who actually used or purchased the goods is material (§ 5b UWG). Competitors can send warning letters, so a missing notice can be costly without any authority acting.
  • Italy. The AGCM enforces the rules through the Consumer Code, as in the EUR 4 million Trustpilot decision above.
  • EU-wide. The Commission's 2024 report cites action by the Polish authority UOKiK against sellers of fake reviews, and a German court ruling that the number of reviews behind an average and the period they cover are material information (COM(2024) 258).
  • United Kingdom, for comparison. The Digital Markets, Competition and Consumers Act 2024 lists fake reviews and concealed incentivised reviews as banned practices in Schedule 20, paragraph 13, and requires publishers of reviews to take reasonable and proportionate steps to prevent and remove them (DMCC Act 2024, Schedule 20), in force since 6 April 2025 (SI 2025/272).

Review apps on Shopify

Most Shopify stores collect reviews through an app. Check four things: can it restrict reviews to buyers, does it mark incentives, can you place your own info text near the reviews, and what does it export if you switch. The app provides the mechanism. The information duty stays with you.

Complimus does not handle reviews. It covers four other EU rules on a Shopify storefront: the Omnibus lowest prior price, GPSR product safety information, the EU legal guarantee notice and the EU withdrawal button (see features). The reviews text is your own or your review app's.

A ready info text template

This is a template. Replace every bracket and delete the lines that do not match what you actually do.

Template

About the reviews on this store

Reviews are collected [by email invitation after a confirmed order / through an open form on the product page / both]. Reviews marked "verified purchase" were submitted through a link connected to an order in this store. [Reviews without that mark may come from anyone.]

We publish all reviews, positive and negative, except reviews that are spam, offensive, unrelated to the product or that we cannot link to a purchase. We do not edit the content of reviews. [We may remove reviews that breach our review terms.]

[Some reviews were imported from (platform or previous store) and are marked as such.] [Customers who leave a review may receive (discount or gift) regardless of the rating. These reviews are marked "incentivised".]

The average rating shows all published reviews for the product [since (date) / over the last (period)].

Merchants who sell in Germany can use the German twin of this guide, Bewertungen kennzeichnen in Shopify, for a German-language version.

Frequently asked questions

Do I need the info text if I show no verified badge?

Yes. Article 7(6) applies whenever you give consumers access to reviews. It asks whether and how you check them. "We do not verify that reviewers bought the product" is a valid answer, as long as you say it and no badge or heading such as "customer reviews" suggests otherwise; a German court (OLG Köln, 20 December 2024, 6 U 59/24) held that heading misleading even next to such a notice.

Can I delete negative reviews?

You can remove reviews for stated reasons such as spam or abuse. Removing reviews because they are negative while presenting the rest as representative misrepresents them under point 23c.

Is a discount code for a review allowed in the EU?

It is not banned by the UCPD, but the incentive must be disclosed, the review marked and the reward must not depend on the rating. Some national rules and platform terms are stricter.

Does Complimus add the reviews text for me?

No. Complimus covers the Omnibus price rule, GPSR, the legal guarantee notice and the withdrawal button. The reviews explanation goes in your review app's widget or in your theme.

Sources

Last checked: 4 November 2026. This guide is general information, not legal advice.

Omnibus, GPSR, guarantee notice, withdrawals.
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