This document outlines the most relevant legal requirements for businesses that collect and publish customer feedback. The text was originally created in 2022 and has been updated to reflect today’s verification standards and legal guidance.
Suggestions for improvements can be sent to [email protected].
In this article, we use the term user reviews to describe ratings and written feedback from consumers. The Norwegian Consumer Agency defines a user review as an «opinion or customer rating from a consumer who has tested, used, purchased or intended to purchase a product or service, and which has been submitted or published to inform other consumers.»
The Norwegian Consumer Agency has again taken the definition from its Danish colleagues in the Consumer Ombudsman and the document «Guidelines for Publishing User Reviews, 1. maj 2015».
In practice, businesses work with many types of user reviews. In Lipscore, we distinguish between product reviews and service reviews, and all feedback is collected only from verified customers.
Two laws are particularly relevant when working with user reviews:
The Personal Data Act (GDPR)
The Marketing Act
The Personal Data Act regulates how personal data must be stored and processed. This is especially relevant for user reviews, which often include personal information such as names and purchase history.
The Schrems II judgment (CJEU) places strict requirements on transferring personal data outside the EEA. According to European and Norwegian authorities, personal data may not be transferred to countries outside the EEA unless an adequate level of protection is ensured.
Lipscore stores all customer data on servers located in Ireland and Norway, and follows the guidance of the The Norwegian Data Protection Authority on secure data storage.
Businesses should ensure that any technical solution they use for collecting user reviews stores and processes personal data in compliance with these regulations.
The Marketing Act is based on the EU directive on unfair commercial practices. The Norwegian Consumer Agency is responsible for ensuring that the law is followed.
Entrepreneurs who use user reviews in their marketing must comply with these rules. Key principles include:
No marketing measure may violate good business practice (§6)
Consumers must not be misled about what the user review refers to (§7)
Marketing must be clearly identifiable as marketing (§3)
The Norwegian Consumer Agency has published guidance for businesses that use customer reviews. Lipscore’s recommendations are based on this guidance and updated EU/Norwegian requirements for transparency and verification.
Only real customers may write reviews. Businesses must not buy fake reviews or encourage employees, suppliers, or partners to write reviews.
Lipscore enforces this by allowing reviews only from verified buyers.
Encouragement to leave reviews must be neutral. Businesses must not ask only satisfied customers to leave feedback.
If rewards are used, terms must clearly state that the chance of receiving the reward does not depend on leaving a positive review.
If a customer receives compensation, rewards, points, or similar benefits for writing a review, this may influence how the review is perceived. Under EU consumer law (Directive (EU) 2019/2161), incentivized reviews must be clearly marked as incentivized, and:
The incentive must be given regardless of whether the review is positive or negative
The value must be small and may not influence the review
The solicitation must be neutral
Customers must be informed that the review is incentivized
Lipscore does not currently offer technical functionality for marking incentivized reviews. Businesses choosing to use incentives are responsible for ensuring that reviews are clearly marked and fully compliant with applicable legislation.
Weak incentives offered neutrally and equally to all customers may qualify as user reviews rather than advertising under many national interpretations, but the exact boundaries depend on how the Omnibus Directive is applied in each country and may evolve as authorities update their guidance.
Lipscore recommends caution when incentivizing reviews, including when incentives are tied to loyalty programs.
The Norwegian Consumer Agency encourages systems that help ensure that reviews come from actual users of a product or service.
Lipscore publishes only reviews from verified customers. Verification is based on a completed purchase and technical identifiers such as the customer’s name, email, or account information as used at checkout. Unlike platforms that accept reviews based on simple login or social media accounts, Lipscore ties every rating and review to a specific transaction, ensuring that the customer has actually purchased the product or service in question.
Retailers are responsible for marketing in their channels, including published user reviews.
In Lipscore, reviews may only be withheld if they contain inappropriate language or violate legal guidelines. Reviews about delivery, service, or pricing may be recategorized from a product review to a service review if more appropriate.
The Norwegian Consumer Agency recommends minimizing moderation, as this affects credibility.
With Lipscore:
Negative reviews cannot be deleted or down-ranked
Reviews are published automatically, with optional short delay for screening for inappropriate language
Only violations of language or legal guidelines may justify withholding publication
Retailers are encouraged to respond to reviews rather than suppress them
If a review is not approved, the customer must be notified and given the opportunity to update it
Consumers typically understand that retailers cannot be held responsible for incorrect claims made in user reviews. However, if a retailer uses customer claims in its own marketing, the retailer may become responsible for those claims.
Reviews must be displayed neutrally and objectively (e.g., by date or relevance). Businesses must not manipulate rankings to create a misleading impression.
The number of reviews or ratings should be shown when summarizing customer sentiment.
Paid or incentivized reviews must be clearly separated from ordinary user reviews, and when published, must be clearly marked as incentivized.
Whether incentivized reviews may be included in aggregated star summaries depends on the interpretation of national consumer law and the nature and value of the incentive. Under the Omnibus Directive, marked incentivized reviews may still qualify as user reviews when the incentive is small, neutral, and offered to all customers regardless of whether the review is positive or negative.
The Norwegian Consumer Agency has not yet updated its guidance for businesses following the implementation of the Omnibus Directive. Until this guidance is updated, it is not clear how strictly incentivized reviews—especially weak or loyalty-based incentives—will be interpreted in practice, including whether they may be included in aggregated summaries. As of today, the legal interpretation is uncertain, and businesses must assess compliance based on the current law and their national enforcement authority’s expectations.
Businesses are responsible for ensuring that any incentivized reviews they publish comply with applicable national rules, including transparency requirements.
Under the Marketing Act, responsibility may extend to individuals and partners involved in violations, including:
General managers
Board members
Agencies
Platforms that facilitate the illegal marketing
At Lipscore, we guarantee that:
We store and process personal information in accordance with applicable privacy laws.
Personal information you store with Lipscore belongs to your company, even after a possible termination of the customer relationship.
We do not monitor personal information.
Our customers and their end customers have the right to export or delete their personal information at their own request.
To become a customer of Lipscore, we expect that:
The company complies with the Marketing Act and the recommendations given by the Norwegian Consumer Agency.
The company uses all the customer insight you get through our tools to create good customer experiences.
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