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Meta description : Review gating prohibited, Omnibus Directive, DGCCRF sanctions up to €300,000... Learn how to legally collect reviews on Google and Trustpilot with Review Collect's Compliant Flow.
Main keywords : customer review compliance, review gating, Omnibus Directive, Omnibus Directive, Google review, Google review, Trustpilot guidelines, legal advice collection, DGCCRF fake reviews, ISO 20488 standard
The world of e-reputation has changed radically. What worked yesterday may now cost you a fine of 300,000 euros, the suspension of your Trustpilot account, or worse: the permanent deletion of your Google Business Profile.
In 2024, Trustpilot removed 4.5 million fake reviews, representing 7.4% of all reviews submitted on the platform. Google has strengthened its algorithms for detecting manipulated review flows. And the Omnibus Directive, which came into force in May 2022, is now fully applied by the DGCCRF with its algorithmic tool “Polygraph”.
In this context, e-commerce brands need to completely rethink their review collection strategy. The Review Gating (filtering reviews based on satisfaction) is now explicitly prohibited by Google, Trustpilot and European regulations.
So how do you effectively collect reviews while remaining 100% compliant? That's exactly what we're going to explore in this comprehensive guide.
La Omnibus Directive is the founding text of European regulations on customer reviews. Transposed into French law by ordinance No. 2021-1734 of 22 December 2021, it came into force on May 28, 2022.
This directive considers unfair commercial practice misleading consumers by indicating that the reviews were submitted by consumers who actually used the product, when there is no reasonable and proportionate measure to demonstrate this.
In concrete terms, the Omnibus Directive prohibits:
Information requirements include:
The article L.121-4 of the Consumer Code Now qualifies fake reviews as deceptive marketing practices. The penalties are severe.
For natural persons (individual entrepreneurs), sanctions can reach 2 years of imprisonment and 300,000 euros fine. For legal persons (SARL, SAS, etc.), the fine may be increased, in proportion to the benefits derived from the offence, to 10% of the average annual turnover.
For “large-scale” infringements at the level of the European Union, the amount of the fine can be up to 4% of average annual turnover.
The DGCCRF has deployed an algorithmic tool called “Polygraph” capable of analyzing language patterns, the frequency of publication and the geographical origin of reviews in real time to detect organized manipulation campaigns.
Since the April 6, 2025, the United Kingdom applies the DMCCA, one of the most stringent online review regulations in the world.
This law prohibits not only the publication of fake reviews, but also the publication of unreported or imported incidental reviews from different product sheets. The Competition and Markets Authority (CMA) can directly impose fines of up to 300,000 pounds, or even 10% of annual turnover.
The DMCCA also requires major platforms to implement robust verification policies, conduct regular internal audits, and publish their moderation procedures.
En August 2024, the American Federal Trade Commission (FTC) adopted a rule explicitly prohibiting the practices of creating, buying, or selling false reviews. Violations may result in civil penalties up to $51,744 per violation.
This FTC rule also reinforces the ban on review gating, stipulating that businesses cannot provide compensation or incentives conditional on writing reviews that express a particular feeling, positive or negative.
The Review Gating (literally “review filtering”) is a practice that consists in orienting the customer journey according to their declared level of satisfaction.
In a classic review gating system, a customer with a 4 or 5 star rating is invited to share their experience on a public platform such as Google or Trustpilot. Conversely, a customer expressing dissatisfaction (1 to 3 stars) is redirected to an internal form or customer service, without ever seeing the option of publishing a public review.
Concrete examples of review gating:
Google is very explicit in its guidelines: review gating is a violation of its terms of use. The Google Reviews policy states that businesses should not selectively solicit positive reviews while removing or preventing negative reviews.
The consequences can be dramatic: removal of all existing reviews, suspension of the Google Business Profile, or even permanent ban from the platform.
En January 2025, Google introduced extended monitoring periods where reported reviews may remain hidden during the review. Google algorithms now analyze review submission patterns, including artificial spikes that suggest automated campaigns and suspicious ratios between positive and negative ratings.
Trustpilot explicitly prohibits the collection of reviews in a “biased or unfair” manner in its Guidelines for Businesses. According to their 2025 transparency report, the platform is now using thegenerative artificial intelligence to identify large-scale policy violations.
What Trustpilot automatically detects:
In 2024, Trustpilot sent educational messages and warnings to companies detected in violation of their guidelines. Repeat offenders risk the blocking of their account, the suspension of functionalities, or even the complete withdrawal of the platform.
La ISO 20488 standard (formerly NF Z74-501 in France) defines the standards for collecting, moderating and distributing authentic reviews. This standard is explicitly mentioned by the Omnibus Directive as a reference for review verification practices.
Key requirements of the standard include full traceability of the origin of reviews, non-discrimination in solicitation (all customers should have the opportunity to leave a review), transparency on moderation methods, and the ability for the author to edit or delete their review.
Companies certified AFNOR NF Online Service Avis (based on ISO 20488) benefit from a guarantee of credibility recognized by regulators and consumers.
Faced with these regulatory constraints, Review Collect has developed the Compliant Flow, a system for collecting opinions based on a total transparency.
The fundamental principle is simple: regardless of the initial score given by the customer, he is offered a neutral choice between two options of equivalent importance.
Option A: Private Mediation (Customer Support)The customer chooses to contact the support team directly to solve a problem or get help.
Option B: Public Publishing (Trustpilot/Google)The customer chooses to share their experience publicly on the review platform of their choice.
This structure ensures thatno customer is prevented from speaking publicly, making Review Collect 100% compliant with third-party platforms' non-filtering clauses and the Omnibus Directive.
Step 1: Initial qualification
The journey starts with a scoring question sent to the customer's preferred channel: WhatsApp, SMS, RCS or Email. This stage collects the immediate feeling without any hindrance as a result of the process.
All customers receive the same solicitation regardless of purchase history or customer value. It is a requirement of the ISO 20488 standard.
Step 2: The neutral choice screen
It's the core of compliance. Unlike review gating systems that automatically redirect, Review Collect displays a screen of Binary choice for each return, regardless of the grade.
The two buttons (Customer Support and Public Release) have a equivalent visual importance. The public option is never hidden, disguised or relegated to the background.
Step 3: Factual information (ethical nudging)
The flow informs the customer about the technical realities of the platforms, without manipulation. For example, on Trustpilot, a customer often posts under a nickname, making it difficult for the brand to identify them. For an urgent problem (lost package, defective product), publishing a public notice is therefore the least effective way to obtain a quick solution.
This factual information naturally encourages unhappy customers to seek support for a Guaranteed resolution, while leaving them the total freedom to choose the public publication.
Impeccable visual neutrality
A lawyer or a DGCCRF controller analyzes what are called “Dark Patterns” (deceptive interfaces). Review Collect avoids these pitfalls by offering buttons of equivalent importance, with clear and non-manipulative labels.
Compliance with article L111-7-2 of the Consumer Code
This article requires fair information on how to deal with reviews. Compliant Flow is the technical response to this obligation, ensuring that access to third-party platforms is never hindered.
Legitimate use of pre-contractual information
Informing the customer that Trustpilot is not transmitting the reviewer's email to the company is a Technical truth. This pre-contractual information helps the user to choose the most suitable channel for their resolution needs. It is not manipulative because it is factual and verifiable.
Google Business Profile:
Trustpilot:
As mentioned earlier, sanctions can reach 300,000 euros fine and 2 years of imprisonment for the most serious cases.
En March 2025, the Paris Court of Appeal issued a significant judgment (no. 22/16356) in the case “La Loco and Le Wagon v. La Capsule”, sanctioning the publication of false anonymous negative reviews aimed at denigrating a competitor. This decision confirms the repressive position of the French courts.
Beyond sanctions, review manipulation practices can destroy consumer trust. According to the Trustpilot 2025 report, 81% of consumers pay attention to the veracity and authenticity of reviews that they consult.
A fake review scandal can be the subject of press articles, bad buzz on social networks, and a lasting loss of credibility.
CriteriaReview Gating (prohibited) Compliant Flow (Review Collect) Compliance Omnibus Directive ❌ Non-compliant ✅ 100% ComplianceGoogle Guidelines ❌ Violation ✅ CompliedTrustpilot Compliance ❌ Violation ✅ ComplierRisk of Sanction ⚠️ High ✅ NulAccess to Sanctions High NulAccess to public platformBlocked for notes < 4Blocked for notes < 4Always availableAlgorithmic detection ⚠️ Probable ✅ No Suspicious SignalDGCCRF Audit CompliedRisk High NulAccess to Public PlatformBlocked for Notes < 4Blocked for notes < 4Always availableAlgorithmic detection Probable No Suspicious SignalDGCCRF Audit Compliance:Risk of Sanction High ⚠️ ✅
Contrary to popular belief, Compliant Flow does not degrade collection performance. On the contrary, by offering an immediate resolution alternative, it potentially turns detractors into promoters.
An unhappy customer who gets a quick resolution via support is often more likely to revise their opinion and ultimately leave a positive review, or even become a brand ambassador.
The first compliance rule is to ask all your customers in a fair manner. You cannot:
Each customer should be able to leave a review on Google, Trustpilot or any other platform, regardless of his satisfaction.
The public publication option should be:
In case of an audit, you must be able to demonstrate your best practices. Keep the following items:
Your marketing teams, customer relations and legal departments must be aware of European regulatory obligations (Omnibus Directive, DSA), French (Consumer Code, DGCCRF) and, for international companies, the British DMCCA.
For the most demanding companies, we recommend integrating a transparency clause into the CGU, specifying the use of a mediation and fair collection tool. This proves the good faith of the advertiser during any audit.
Yes, because it is a verifiable technical truth. Trustpilot does not actually transmit the email address of the reviewer to the company for privacy reasons. The information provided by Review Collect is therefore pre-contractual information necessary to allow the user to choose the channel most suited to their needs.
Because the law does not require inefficiency. It obliges the Loyalty. Offering immediate support is a service provided to the customer. As long as the path to Trustpilot remains open and fairly presented, the company is meeting its obligations.
Not necessarily. Experience shows that very unhappy customers who get a quick resolution via support often become promoters. In addition, an authentic flow generates a more natural distribution of reviews, which reinforces the credibility perceived by consumers.
Review Collect maintains comprehensive logs of all customer journeys, showing that:
These elements constitute irrefutable proof of good faith.
Online reputation is no longer built on covering up problems, but on ability of a brand to solve them. Consumers in 2025 are more savvy than ever: they know how to recognize profiles that are “too perfect” and are wary of exclusively positive ratings.
By adopting a compliant approach like Review Collect's Compliant Flow, you're not just avoiding fines or bans. You are building a lasting relationship of trust with your customers and with review platforms.
The companies that will win the reputation battle are the ones that will transform regulatory constraints into Lever of differentiation. They will show their customers that they have nothing to hide, and that their satisfaction is a top priority.
Review Collect: Performance, Loyalty, Security.
Article updated in January 2026 • Review Collect
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