Fake reviews on online platforms: perspectives from the US, UK and EU legislations

User-generated online reviews have become essential sources of information for potential consumers. Given the increasing importance of online reviews on consumer purchases, some traders try to publish or promote fake reviews on online platforms to improve the reputation of their goods or services, or to damage the reputation of their competitors. This paper aims (1) to analyse whether and how fake reviews violate the main legal and ethical principles of advertising, according to the legislations of the US, UK and EU as well as the International Advertising and Marketing Communications Code; (2) to assess how the EU, the UK and the US are dealing with them, and find out which approaches and actions are working best; and (3) to offer normative recommendations for effective prosecution of fake reviews. The paper uses a combination of theoretical and sociological approaches (section 1), black letter analysis of law (sections 2 and 3) and a comparative approach (sections 2 and 3). Among others, the article observes (1) that fake reviews are a form of illegal advertising and (2) that the European regulatory instruments provide more protection against fake reviews than the US and argues (3) that an effective fight against fake reviews requires strong administrative bodies, endowed with sufficient resources.