Day 156: Commission Genuine Customer Reviews, Not Synthetic Advocacy
Consider a fictional proposal for a UK consumer-facing review campaign. An agency promises to “scale public brand sentiment and review velocity for AI answer engine discovery”. Its plan includes social-media recruitment, free samples tied to five-star ratings, and consumer-style testimonials generated under simulated profiles.
This is not a delivered campaign or an enforcement finding. It is a procurement test: which conduct should a marketing leader reject, and what should they request instead?
The legal boundary matters. The Competition and Markets Authority’s CMA208 guidance explains the UK prohibition on submitting or commissioning fake reviews and concealed incentivised reviews. It also distinguishes those practices from encouraging accounts of genuine experiences without predetermining their content or sentiment.
The red lines below are ZSA’s proposed procurement standard, informed by that guidance. They are not legal advice.
Evaluate the conduct, not the AI vocabulary
1. Free products in exchange for five-star reviews
Decision: reject.
The proposed rating is predetermined rather than an independent account. CMA208 gives closely matching examples: offering a free or discounted product for a five-star review that does not reflect the person’s genuine experience, and requesting a review of a free or discounted product without making clear that the incentive must be disclosed.
The distinction is not simply “incentive or no incentive”. An incentivised review must still reflect a genuine experience, and where such reviews are permitted they must be prominently identified as incentivised—namely, as an advert. The guidance also warns that many review platforms do not permit incentivised reviews at all. Disclosure is not universal permission.
2. Generated testimonials under simulated customer profiles
Decision: reject.
These are fabricated experiences masquerading as individual consumer accounts. CMA208 covers buying reviews that appear consumer-written but were generated by software, selling such reviews, and services designed to facilitate banned reviews or evade detection.
That does not establish a blanket ban on software helping a real customer draft an account of a genuine experience. The problem in this proposal is the invented customer experience and simulated identity—not the mere presence of software.
3. Invitations for genuine, unconditioned feedback
Decision: request a rewritten brief with safeguards.
CMA208 says businesses may encourage reviews of genuine experiences where they do not predetermine the content or sentiment. A genuine experience need not be limited to a verified purchase; it can include, for example, a gifted or incomplete experience.
As a procurement safeguard, ZSA would ask the agency to use a defined, viewpoint-neutral invitation policy—for example, inviting the full eligible customer cohort rather than selecting likely advocates. That is our proposed control, not a universal statutory requirement.
The brief should also prohibit selective suppression of genuine criticism. That need not prevent reasonable, proportionate investigation or temporary withholding while a review is assessed under a lawful moderation process.
The bounded GEO connection
CMA208’s scope includes individual reviews, aggregate ratings and review summaries. It also says publishers should have processes to correct AI-generated review summaries that have been affected by banned reviews. That is a documented connection between review integrity and AI-derived presentation.
It is not evidence that review volume, star ratings or incentives make an answer engine cite, rank or recommend a brand. The agency has offered no basis for that outcome. Even if reviews can appear in AI-mediated discovery, a possible visibility benefit cannot make fabricated advocacy acceptable.
Procurement decision
Reject this proposal’s fabricated testimonials and rewards conditioned on five-star ratings. Ask for a replacement brief centred on genuine experiences, no predetermined sentiment, clear treatment of any incentives, platform-compatible collection, viewpoint-neutral invitations and proportionate moderation.
The commercial decision comes before the channel promise: do not commission purported customer experience that the customer never supplied.