Online reviews in Italy | A new compliance framework

The Italian Competition and Market Authority (Autorità Garante della Concorrenza e del Mercato) has concluded the consultation launched in July 2026 and has adopted, by Resolution no. 32067 of 13 October 2026, guidelines "aimed at guiding businesses in adopting appropriate measures to ensure compliance with the legality requirements for online reviews" .

Context, purpose and scope

The Consumer Code classifies the following as unfair commercial practices, and accordingly prohibits traders from: 

• stating that reviews of products or services have been submitted by consumers who have actually used or purchased the product, without taking reasonable and proportionate steps to verify that this is the case; and
• submitting — whether directly or through intermediaries — false consumer reviews or ratings, or providing false information in relation to consumer reviews or ratings.
   

Law no. 34/2026 further introduces specific rules governing online reviews relating to products, services, and facilities offered by catering businesses and tourism establishments located in Italy.

Specifically, it provides that online reviews are lawful where: 

• they are posted within 30 days of the date on which the product was used or the service was received; 
• they are submitted by individuals who have actually used the product or service in question; 
• they are relevant to the type of product used or service received; and 
• they are not posted in exchange for discounts, benefits, or other advantages offered by the provider.

The law further specifies that online reviews are presumed to be lawful where supported by receipts or other tax documentation evidencing the purchase, and must in any event be removed two years after their publication.

The Authority was required by the law to adopt the guidelines, which are therefore primarily directed at combating unlawful reviews in the tourism and catering sectors. The Authority has nonetheless clarified that the guidelines "provide an interpretative aid that applies [...] to every other product sector as well".

Key provisions of the guidelines

The guidelines adopt a broad definition of "reviews", encompassing "any judgement, opinion or assessment expressed online on dedicated channels and platforms, in any form, by consumers in relation to goods or services or to the quality and performance of the trader offering them".

The guidelines set out principles applicable to two categories of traders:

• traders who provide tools for reviewing their own goods and services (including those who play an active role in hosting reviews of goods and services offered by third parties); and
• traders who provide services for publishing or managing reviews relating to goods or services offered by third parties.
   

Obligations for traders providing review tools

Traders who provide tools for reviewing their own goods and services must provide clear and easily accessible information on how reviews are published, managed, categorised, and moderated, as well as on the criteria for classifying them as "verified" or "authentic". This information must be within the same interface used for publishing reviews, including via a link. Where review scores are used, traders must also specify whether they are "influenced by incentivised reviews or other types of contractual relationships".

Traders must take reasonable and proportionate measures to ensure that reviews are lawful, having regard to "the nature of the activity carried out and the economic scale of the business", as well as "the need not to discourage their publication". By way of example and without limitation, the guidelines identify three categories of such measures:

• Verification of use or purchase: tools designed to verify that the consumer has actually used or purchased the product or service being reviewed (for example, requesting tax documentation certifying the purchase; sending a review link to the email address used at the time of purchase only upon order completion; collecting reviews via the customer's private account in the "completed orders/bookings" section; or using dedicated channels authenticated via QR codes or one-time password (OTP) systems;
• Traceability of review authors: tools designed to ensure that the author of a review can be identified (for example, registration systems, confirmation links sent to the email address provided, and IP address checks); and
•  Detection of fraudulent activity: automated tools to identify anomalous signals indicative of fraudulent conduct (for example, a high volume of reviews posted within a short period of time from the same IP address).
   

Traders must also refrain from manipulating reviews in any manner — for example, by removing or concealing negative reviews, discouraging the publication of negative reviews, or providing pre-written templates for positive reviews.

The same principles apply to traders who host reviews relating to goods and services offered by third parties.

For large platforms — which present a heightened risk of fraudulent activity and have greater resources available — the requisite measures may include more sophisticated methods, such as artificial intelligence systems complemented by human review of content.

Complaint handling and removal of unlawful reviews

Traders must handle complaints in a timely and transparent manner and promptly remove any unlawful reviews. In particular, traders are required to:

• remove without delay any reviews whose unlawfulness is immediately apparent; and
• afford both the author and any party contesting the authenticity of a review the opportunity to substantiate their respective positions where the unlawfulness is not immediately apparent.
   

In all cases, requests for removal must be sufficiently precise and adequately justified.
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Osborne Clarke comment

The guidelines represent a significant step towards comprehensive regulation of online reviews in Italy. Although they were adopted in implementation of the law and are therefore primarily directed at the catering and tourism sectors, the Authority's clarification that they apply across all product sectors considerably broadens their practical scope. 

Affected businesses should therefore assess and revise their internal review management processes, with a view to ensuring full compliance with the guidelines and reducing the risk of enforcement action by the Authority.