Misleading practices on digital platforms: lessons from Trustpilot

In March 2026, the Italian Competition Authority ("AGCM") found that Trustpilot Group Plc, Trustpilot A/S, and Trustpilot S.r.l ("Trustpilot"), which operate a popular digital review platform that hosts profiles of over 1.27 million companies worldwide, engaged in unfair commercial practice. AGCM imposed a fine totalling EUR 4,000,000.

The Trustpilot platform allows individuals to rate products and services on a scale from one to five, thereby shaping perceptions of business reliability and customer satisfaction. At the same time, the platform is directed at businesses, providing a range of services designed to enhance visibility and perceived trustworthiness. In its investigation, AGCM found that, in the way this business model was set up, Trustpilot:

• did not adequately inform consumers of the ability of businesses to affect their own ranking and rating on the platform;
• led consumers to believe, contrary to the truth, that it adopted every measure to ensure that the reviews on the platform reflected representative and authentic experiences; and
• only in a fragmented and not immediately accessible manner provided consumers with relevant information about how the platform functions and the elements relevant to making their choices of products and services.

Lack of adequate disclosure of businesses' ability to affect the ranking and ratings

Trustpilot made it difficult for consumers to understand that the ratings and rankings on the platform were significantly shaped by the businesses, pursuant to arrangements authorised by Trustpilot.

Firstly, if a business confirms its profile, it may respond to customer reviews and invite customers to leave feedback. However, an individual using the Trustpilot platform could learn about that prerogative only if he or she positioned the cursor over the label "claimed profile", appearing in small letters at the top of the business's profile page.

Then, more detailed information was hidden in the section "How this company uses Trustpilot", accessible only by clicking a side link on the profile page. Within that section, the wording "Pays to have access to extra Trustpilot features" appeared, but the main profile page contained only the generic phrase "Trustpilot subscription active". Until 18 January 2026, the phrase "Trustpilot subscription active" was visible only after scrolling, displayed in light‑coloured characters and without visual prominence. After 19 January 2026, Trustpilot modified the disclosure, adding the wording "Paid Trustpilot subscription" next to the "claimed profile" label at the top of the page. However, AGCM concluded that even this change remained incomplete, as consumers were not informed of the specific services included in each type of paid subscription plan or of the benefits businesses obtained.

AGCM found that Trustpilot failed to provide consumers with clear and accessible information about the existence and impact of businesses' paid subscription plans. Trustpilot offers several paid plans, each with different caps on the number of invitations to send to consumers to review and each with additional services. Trustpilot did not explain that the ability of a business to collect customer reviews may help the business to appear in a more favourable light on the platform, how the various subscription plans impact the business's ability to collect reviews, and to which plan the particular business has subscribed.

Contrary to Trustpilot’s assertion in the proceedings that subscription type had no impact on consumer assessment, the investigation showed that:

• more expensive plans allowed businesses to send more invitations to review, increasing the number of reviews collected;
• a higher number of invited reviews affected the quantity of reviews labelled as "verified";
• invited reviews influenced the TrustScore, the numeric score representing the customer rating; and, as a consequence
• the positioning of businesses in category rankings was affected, since rankings depended on both TrustScore and the number of published reviews.

AGCM concluded that the lack of adequate disclosure deprived consumers of essential information. By failing to explain how paid services could shape scores and rankings, Trustpilot misled users into believing they were viewing an objective representation of customer satisfaction, when in fact these elements were materially influenced by subscription plans.

Misleading impression of representativeness and authenticity of reviews

According to AGCM, Trustpilot created a misleading impression that all reviews on its platform reflected authentic and organic consumer experiences. By portraying itself as neutral and trust‑based, while simultaneously offering paid services that distorted review outcomes, Trustpilot misled consumers about the reliability of businesses reviewed on its platform.

The system allowed companies to selectively amplify positive feedback and suppress less favourable experiences. Businesses' reviews on the platform are divided into three categories: (i) organic reviews, submitted spontaneously by consumers, (ii) verified reviews, marked with the "verified" label, and (iii) invited reviews, marked with the "invited" label. Businesses derived greater benefit from "verified" and "invited" reviews, which tended to be more positive than organic reviews. Paid services enabled businesses to collect a significantly higher number of "verified" or "invited" reviews, while free plans imposed strict limitations.

The investigation showed that Trustpilot allowed the businesses on a subscription plan to present a review as "verified" even though the review was not verified in any meaningful sense. As the "verified" reviews are, for the most part, positive, and the platform users are likely to take "verified" reviews as authentic, the overall effect was that the users were misled as to the actual consumer experience with businesses' products or services. On Trustpilot’s platform, it was represented that the mark "verified" means that Trustpilot has verified that its author had an authentic experience with the business in question. However, in practice, Trustpilot allowed the businesses to use the label even where there was any interaction whatsoever between the consumer and the business (including a welcome email sent by the business to the consumer).

Fragmented and non‑accessible information

Information provided to consumers was scattered across different sections of the Trustpilot website and not immediately accessible, which led AGCM to conclude that consumers were not appropriately informed about how the platform functions and the elements relevant to making their choices of products and services. For example, details about the calculation of a business's TrustScore were only available through a series of steps: clicking on an informational pop‑up, then selecting "learn more" to be redirected to a separate page explaining that the TrustScore is a weighted calculation based on factors such as the number and timing of reviews. The platform also notes that whether a business actively invites customers to write reviews influences the TrustScore, but this disclosure was also hidden behind multiple layers of navigation.

Similarly, within each business profile, consumers could access the section "How this company uses Trustpilot" to learn whether the company had claimed its profile, subscribed to a paid plan, or actively invited customers to leave reviews. However, this section was distinct from the main profile page, meaning that the most relevant information about how a company used Trustpilot’s services was not presented upfront. As mentioned above, even after the changes made in January 2026 to give greater prominence to this section, AGCM found that consumers were still not informed of the specific type of paid plan or the additional services used.

Overall, AGCM concluded that Trustpilot’s fragmented and non‑prominent disclosures created confusion and lacked clarity and transparency. Consumers were guided to focus on the TrustScore, the number of reviews, and "verified" labels, all elements influenced by paid services, while the information necessary to understand how these outcomes were shaped was hidden or incomplete.

Comment

This case underscores the importance of transparency in digital platforms. Consumers rely heavily on online reviews when making purchasing decisions. When the mechanisms behind those reviews are obscured or manipulated, the very foundation of consumer protection is undermined.

AGCM determined that Trustpilot’s overall business model amounted to a misleading commercial practice under Articles 20-23 of the Italian Consumer Code. Consumers were misled about the reliability of the businesses reviewed and the actual level of satisfaction with their products and services.