Proving trust online: what regulators and search engines now expect

For years the trust section of a financial website looked much the same: award badges, a 4.9 star rating, “trusted by thousands of clients” and a strip of “as featured in” logos. These signals were cheap to add and hard for a visitor to check.

That is changing from two directions. Regulators in the US, the EU and the UK now have specific rules on reviews, endorsements and hidden advertising. And Google tells its quality raters to treat what a site says about itself with caution. For regulated firms, whose subject matter Google treats as high stakes, both matter.

This is a general overview, not legal advice: take legal advice for your own situation.

What regulators now prohibit

United States: the FTC rule on reviews and testimonials

The US Federal Trade Commission announced its final rule banning fake reviews and testimonials on 14 August 2024, after a 5 to 0 vote[1]. The rule went into effect on 21 October 2024[2].

It prohibits:

• creating or selling fake reviews and testimonials, including those that “misrepresent that they are by someone who does not exist, such as AI-generated fake reviews”, or buying or spreading them when the business knew or should have known they were fake[1];
• compensation or incentives “conditioned on the writing of consumer reviews” that express a particular sentiment, positive or negative[1];
• reviews by company insiders that “fail to clearly and conspicuously disclose” their material connection to the business[1];
• claiming that a website the business controls “provides independent reviews or opinions” on a category including its own products[1];
• suppressing negative reviews through “unfounded or groundless legal threats, physical threats, intimidation, or certain false public accusations”, or misrepresenting that the reviews shown are all or most of those received[1];
• buying or selling fake indicators of social media influence, such as bot-generated followers or views, for a commercial purpose[1].

There is no general duty to investigate every review, but where there are clear signs that purchased reviews are fake, “failing to investigate may trigger liability”[2].

The rule lets the FTC seek civil penalties against knowing violators[1]. In December 2025 FTC staff sent warning letters to 10 companies, noting that violations can bring “civil penalties of up to $53,088 per violation”[3].

European Union: reviews and hidden advertising

In the EU, the Unfair Commercial Practices Directive (UCPD) was amended by the Omnibus Directive (EU) 2019/2161, which member states had to apply from 28 May 2022[4].

The central duty is transparency about verification. Where a trader gives access to consumer reviews, information about “whether and how the trader ensures that the published reviews originate from consumers who have actually used or purchased the product” counts as material information[4]. Where checks exist, the recitals say traders should explain them, including whether all reviews, positive and negative, are posted[4].

Two practices joined the list of practices that are always unfair:

• stating that reviews come from real users or buyers “without taking reasonable and proportionate steps to check” that they do[4];
• submitting or commissioning false consumer reviews or endorsements, or misrepresenting reviews or social endorsements, to promote products[4]. The recitals say this covers fake “likes” on social media and publishing only positive reviews while deleting negative ones[4].

The original blacklist already covered familiar trust signals. It bans paid editorial content that does not make the payment clear (the “advertorial”), displaying a trust mark or quality mark without authorisation, claiming an approval or endorsement that a public or private body has not given, and falsely representing oneself as a consumer[5]. Courts or authorities can also require a trader to provide evidence for factual claims, and may treat a claim as inaccurate if that evidence is missing or insufficient[5]. An “award-winning” line needs an award behind it.

For widespread infringements handled through coordinated EU enforcement, maximum fines must be at least 4% of the trader’s annual turnover in the member states concerned, or at least EUR 2 million where turnover information is not available[4].

United Kingdom: the DMCC Act 2024

Schedule 20 of the UK’s Digital Markets, Competition and Consumers Act 2024 bans submitting or commissioning a fake consumer review, or one that “conceals the fact it has been incentivised”[6]. It also bans publishing reviews in a misleading way, such as removing negative reviews while publishing positive ones, or “giving greater prominence to positive consumer reviews over negative ones”[6]. Anyone publishing reviews must take “reasonable and proportionate steps” to prevent fake or concealed incentivised reviews and to remove them[6]. Paid editorial content that does not make the payment clear is banned too[6].

These review practices became banned practices in April 2025, and the Competition and Markets Authority (CMA) can impose fines of up to 10% of global turnover[7]. In March 2026 the CMA opened investigations into five businesses over concerns including 1-star reviews left out of ratings, staff asked to write positive reviews and discounts offered for 5-star reviews, stressing it had reached no conclusions[7]. An earlier sweep of over 100 review publishers led to advisory letters to 54 firms[7].

Financial firms: finfluencers and promotions

Financial regulators add their own layer. ESMA’s January 2026 factsheet for finfluencers says anyone paid or otherwise benefiting should “say it loud and clear”, using words such as “Ad”, “Paid partnership” or “Sponsored”: “Not in tiny text. Not just hashtags.”[8]. Telling people what to invest in can count as investment advice, which needs a licence, and a “This is not investment advice” disclaimer will not protect the poster[8]. Promoters should also check that a firm is authorised before posting about it[8].

In Cyprus, CySEC has warned that social media posts giving advice or ideas about buying or selling financial instruments may be investment recommendations under the Market Abuse Regulation[9]. Administrative sanctions in Cyprus for breaching the investment recommendation regime can reach EUR 500,000 for individuals and EUR 1,000,000 for legal persons[9]. CySEC’s review of 2025 names the promotion of investment products by finfluencers among the emerging challenges its supervision focused on[10].

The people who promote a regulated firm are part of its trust signal, and its risk.

What search engines look for

Trust sits at the centre of E-E-A-T

Google says its systems try to identify content that shows experience, expertise, authoritativeness and trustworthiness, which it calls E-E-A-T, and that of these, “trust is most important”[11]. E-E-A-T is not a specific ranking factor in itself, but Google gives it more weight on topics that could significantly affect people’s “health, financial stability, or safety”, which it calls Your Money or Your Life (YMYL) topics[11]. Human quality raters do not control rankings, and their data “is not used directly” in ranking algorithms[11].

The Search Quality Rater Guidelines, dated 11 September 2025, are blunt: “Trust is the most important member of the E-E-A-T family”, because untrustworthy pages have low E-E-A-T however expert they seem[12]. They list financial security as a YMYL category and give “how to invest money” as a topic where inaccurate content could cause harm[12].

Independent evidence beats self-description

Raters are told to “be skeptical of claims that websites make about themselves, particularly when there is a clear conflict of interest”, and, where a site and reputable independent sources disagree, to “trust the independent sources”[12]. Reviews from “an influencer who is paid to promote the product” count as less trustworthy because of that conflict[12]. On customer reviews, raters are reminded that anyone can write them, including the website owner, and that a few negative reviews are “completely normal and expected”[12].

A disclaimer alone does not fix the problem. One example rated Lowest is a sponsored article on a news site that “appears to be an independent review” of a supplement but was written by its producer, and could be mistaken for the newspaper’s own work despite a disclaimer[12].

Reviews and authorship

Google’s reviews system aims to reward reviews with “insightful analysis and original research”, and does not evaluate third-party reviews posted by users[13]. Its advice for reviewers includes showing expertise, giving evidence of your own experience and discussing benefits and drawbacks[14]. More broadly, Google asks whether it is “self-evident to your visitors who authored your content”, whether pages carry a byline where one might be expected, and whether content offers clear sourcing[11].

What builds checkable trust

The common thread: a claim is worth what a reader can check.

Verification anyone can check

Swap badges for evidence. Link your licence number to the regulator’s public register. If an independent body audits or rates you, link to the full published report. This fits both the EU ban on unauthorised trust marks[5] and Google’s preference for independent sources[12]. For trading firms facing sceptical clients, our guide to rebuilding trust in a trading brand applies this to loss figures, licences and payouts.

Clear disclosure of paid content

Label sponsored articles, affiliate arrangements and finfluencer posts in plain words[8]. Paid coverage presented as editorial is banned in both the EU and the UK[5][6].

Named authors and sources

Put a name, a role and a short biography on every substantive article, and cite your sources[11].

Consistent registration and licence details

Your legal name, licence number and regulator should match across your website, social profiles and partner pages. Raters expect it to be clear who is responsible for a website[12], and promoters are told to check authorisation[8].

Responding to criticism

Keep negative reviews visible and answer them. Silencing critics with threats, or removing negative reviews while keeping positive ones, breaks the US and UK rules[1][6], and raters expect any real business to attract some criticism[12].

A correction policy

Publish how you handle errors and date your corrections. Google asks whether content has “any easily-verified factual errors”[11]; a visible correction record shows that you fix them.

A trust checklist

1. List every “award-winning”, “trusted by” and “as featured in” claim. Can you evidence each one today, and was any of that coverage paid for?
2. Next to reviews or star ratings, do you say whether and how you check that reviewers are real customers?
3. Do your ratings include negative reviews, shown with the same prominence as positive ones?
4. Were any reviews gathered with discounts or other rewards? Is that disclosed, and did the reward depend on the rating?
5. Have staff, relatives or partners left reviews without disclosing the connection?
6. Are sponsored articles, affiliate links and finfluencer posts labelled in plain words such as “Ad” or “Sponsored”?
7. Do your legal name, licence number and regulator match across your site, social profiles and partner pages?
8. Does each article have a named author and sources, and is there a public correction policy?