Fake Consumer Reviews: Enforcement Practice of the Bulgarian Consumer Protection Commission
Fake Consumer Reviews: Enforcement Practice of the Bulgarian Consumer Protection Commission
February 2026
Trayan Targov, Senior Associate
BOYANOV & Co.
Online shopping is now part of everyday life across Europe, and Bulgaria is also progressing steadily in this area. As of 2024, 73% of Europeans purchased goods or services online compared to approximately 50% of Bulgarians, leaving substantial potential for future growth (European E‑commerce Report 2025).
As e-commerce expands, consumer reviews have become a key driver of online purchasing decisions, especially when product quality or performance cannot be judged from the trader’s description or brand alone.
Consumer reliance on reviews, however, carries certain risks: if online reviews are fabricated, selectively presented, or displayed without adequate checks, they can distort consumer choice and mislead consumers, as well as create legal and reputational risks for businesses.
Ensuring a fair and transparent e-commerce environment in the area of consumer reviews should, therefore, remain a priority for Bulgarian authorities and consumer organisations. In practice, however, publicly available enforcement remains limited.
The Bulgarian Consumer Protection Commission (the “Commission”) has published on its website two final prohibition orders concerning misleading practices involving product reviews: Order No. 1627 of 8 August 2024 and Order No. 507 of 24 June 2024. These two cases provide a useful snapshot of how review-related infringements were pursued.
1. What product-review practices are prohibited?
Bulgarian law aims to ensure that consumers can rely on authentic product reviews. Following the latest amendments to the Unfair Commercial Practices Directive (2005/29/EC), implemented through the Bulgarian Consumer Protection Act, the review-related rules focus on two core areas: (i) transparency of trader’s review policy, including a ban on unverified “real purchaser” claims; and (ii) a ban on fake or manipulated reviews.
- Unverified “real purchaser” claims
Where a trader provides access to product reviews, it must disclose whether it guarantees that the reviews are from actual purchasers and, if so, how authenticity is verified. The trader should also explain its review handling policy, including whether all reviews (positive and negative) are published and whether any are sponsored or otherwise influenced by contractual relationships.
Traders must not claim that product reviews were submitted by consumers who actually used or purchased the product unless they have taken reasonable and proportionate steps to verify this; doing so is qualified as a misleading commercial practice and is prohibited.
- Fake or manipulated reviews
Traders must not publish (or arrange for others to submit) false consumer reviews or endorsements, nor manipulate consumer reviews or social endorsements to promote products (e.g. by publishing only positive reviews or deleting negative ones). This also constitutes a misleading commercial practice and is expressly prohibited.
2. What unlawful practices did the regulator identify?
In both cases, the Commission examined online stores making health‑related product claims and found that traders had published consumer reviews in a misleading manner.
In the first case – classified as unverified reviews – the trader marketed an “anti‑stress” product purported to stop panic attacks and anxiety. The website displayed positive testimonials that appeared with Bulgarian first and last names preceded by “@” (e.g. “@victordenkov”). The Commission found these reviews to be overtly promotional, portraying the product as a miracle remedy for anxiety, panic attacks, and depression – conditions typically requiring professional treatment.
The Commission concluded that, since no verification measures were in place, the trader could not ensure that the reviews reflected the experiences of real consumers.
The second case – classified as fake reviews – concerned a product marketed to improve vision. The Commission established that the reviews were artificially generated because identical testimonials appeared on mirror websites for the same product in North Macedonia and Croatia, with the reviewer names localised to traditional names in each jurisdiction (e.g. “Krasimir” in Bulgaria, “Mile” in North Macedonia, and “Mihovil” in Croatia). This cross-border duplication was treated as an objective indicator that the content was not genuine user feedback. The Commission therefore concluded that these reviews did not originate from real consumers who purchased or used the product.
In both cases, the Commission reaffirmed the principle that any review presented by a trader as information provided by a consumer must genuinely reflect the opinions, assessments, beliefs, or experiences of real consumers. The Commission found that the reviews in both cases created the overall impression that they originated from independent, impartial consumers and were therefore capable of influencing product presentation and ratings. As a result, the Commission found that these reviews could further influence and motivate the average consumer in their transactional decision to purchase the product.
The Commission appears to have taken the view that the identical reviews appearing under different names across various language versions of mirror websites constituted sufficient evidence of fabricated reviews. By contrast, where the origin of the reviews could not be established at all (even though they appeared fabricated for promotional purposes) the Commission classified the conduct as involving unverified reviews, focusing on the trader`s failure to implement reasonable verification measures rather than establishing an intent to produce fake reviews.
Whether the second case could also have been classified as involving fake reviews is debatable. The distinction applied by the Commission raises questions about the threshold for determining when a review is “fake” versus merely “unverified”, particularly where the practical effect on consumers is similar, but the evidentiary basis and the sanctions legal basis differ. Further decisions will show how the Commission’s practice develops and whether consistent criteria emerge to distinguish the two categories.
3. How did the cases reach the regulator?
Both proceedings were initiated by complaints. In one case, an individual consumer submitted screenshots and links to the relevant website. In the other, the Bulgarian Active Consumers Association, a member of international consumer networks, submitted a detailed, substantiated complaint.
In response, experts from the Directorate for Consumer Protection in Distance Selling – a specialised unit within the Consumer Protection Commission – conducted inspections. Notably, the unit has a team of 11 officials, responsible for nationwide online oversight and for enforcing the entire set of rules of the Consumer Protection Act in distance sales.
Taken together, the limited staffing and the complaint-driven nature of both cases suggest a primarily reactive approach to unlawful product-review practices on e-commerce websites. This illustrates that review enforcement is currently driven more by external signals than by systematic monitoring. Nevertheless, consumer NGO involvement may partly mitigate this by surfacing problematic practices to the Commission.
4. How did the regulator conduct the investigations?
First, the Commission sought information about the trader operating the online store. When this information was not available on the website (as required by Bulgarian law), the Commission reviewed the website’s technical details, including its domain registration, DNS records, IP address, and hosting provider.
During its investigation, the Commission made a test purchase via the website’s order form, with delivery by courier. The Commission then required information from the courier companies to identify the traders responsible for dispatching the goods.
To confirm the sender’s identity beyond doubt, the regulator requested a range of documents and information from the couriers, including a copy of the contract with the sender, the waybill, and payment records, such as cash‑on‑delivery receipts or IBANs used for bank transfers. Notably, in both cases the Commission also requested a comprehensive log of all parcels sent by the same sender during the previous 12 months, which enabled it to build a complete picture of the trader’s activity.
In both cases, the traders responsible for the misleading practices were registered in Bulgaria, although one of them operated via websites with a US-registered domain and hosting based in the Netherlands.
To confirm the operators’ identities beyond doubt, the Commission consulted the Bulgarian Commercial Register to ensure that the entities behind the online stores were correctly identified.
5. What are the consequences for businesses that breach consumer-review prohibitions?
Enforcement typically combines (i) an immediate prohibition order, (ii) a financial penalty, and potentially (iii) corrective publicity and follow-on consumer claims.
When the Consumer Protection Commission identifies misleading commercial practices involving consumer reviews, its primary response is to issue a prohibition order to stop the practice immediately. Under the Consumer Protection Act, these orders are the central remedy for addressing unfair commercial practices and are enforceable immediately even if the trader appeals; failure to comply with such an order is a separate offence that exposes legal entities to penalties, ranging from approximately EUR 1,000 to EUR 35,000.
In addition to the prohibition orders, the Commission may impose administrative penalty for the unfair practice itself, ranging from approximately EUR 1,000 to EUR 25,500.
Therefore, financial exposure typically arises in two ways: (a) fines for the unfair practice, and (b) separate penalties for breaching an enforceable prohibition order or other orders. Repeat infringements may result in the penalty being doubled.
A practical example of the Commission’s approach to setting fines is illustrated by the fake-reviews case, in which a fine of approximately EUR 2,000 – slightly above the minimum – was imposed for the unfair practice alongside the prohibition order and was subsequently upheld by the courts (Judgment No. 1669/05.05.2025 of the Sofia Regional Court under administrative-penalty case No. 15684/2024 and Judgment No. 34879/24.10.2025 of the Sofia Administrative Court under administrative case No. 6572/2025).
Furthermore, in case of misleading commercial practices, the Commission may require the trader or its advertising agency to publicise, at its expense, the prohibition order and a corrected advertisement. Although this corrective publicity has not been applied in the cases cited above, it remains a significant potential consequence for established brands.
Once a prohibition order becomes final, the legal pressure may shift to the consumer level, as consumers gain the right to demand price reductions, cancel their contracts, or claim damages.
Overall, this legal framework is designed to stop unlawful behaviour swiftly and creates substantial financial and reputational risks – making robust controls over consumer-review systems and due diligence essential.
February 2026
Trayan Targov, Senior Associate
BOYANOV & Co.
Online shopping is now part of everyday life across Europe, and Bulgaria is also progressing steadily in this area. As of 2024, 73% of Europeans purchased goods or services online compared to approximately 50% of Bulgarians, leaving substantial potential for future growth (European E‑commerce Report 2025).
As e-commerce expands, consumer reviews have become a key driver of online purchasing decisions, especially when product quality or performance cannot be judged from the trader’s description or brand alone.
Consumer reliance on reviews, however, carries certain risks: if online reviews are fabricated, selectively presented, or displayed without adequate checks, they can distort consumer choice and mislead consumers, as well as create legal and reputational risks for businesses.
Ensuring a fair and transparent e-commerce environment in the area of consumer reviews should, therefore, remain a priority for Bulgarian authorities and consumer organisations. In practice, however, publicly available enforcement remains limited.
The Bulgarian Consumer Protection Commission (the “Commission”) has published on its website two final prohibition orders concerning misleading practices involving product reviews: Order No. 1627 of 8 August 2024 and Order No. 507 of 24 June 2024. These two cases provide a useful snapshot of how review-related infringements were pursued.
1. What product-review practices are prohibited?
Bulgarian law aims to ensure that consumers can rely on authentic product reviews. Following the latest amendments to the Unfair Commercial Practices Directive (2005/29/EC), implemented through the Bulgarian Consumer Protection Act, the review-related rules focus on two core areas: (i) transparency of trader’s review policy, including a ban on unverified “real purchaser” claims; and (ii) a ban on fake or manipulated reviews.
- Unverified “real purchaser” claims
Where a trader provides access to product reviews, it must disclose whether it guarantees that the reviews are from actual purchasers and, if so, how authenticity is verified. The trader should also explain its review handling policy, including whether all reviews (positive and negative) are published and whether any are sponsored or otherwise influenced by contractual relationships.
Traders must not claim that product reviews were submitted by consumers who actually used or purchased the product unless they have taken reasonable and proportionate steps to verify this; doing so is qualified as a misleading commercial practice and is prohibited.
- Fake or manipulated reviews
Traders must not publish (or arrange for others to submit) false consumer reviews or endorsements, nor manipulate consumer reviews or social endorsements to promote products (e.g. by publishing only positive reviews or deleting negative ones). This also constitutes a misleading commercial practice and is expressly prohibited.
2. What unlawful practices did the regulator identify?
In both cases, the Commission examined online stores making health‑related product claims and found that traders had published consumer reviews in a misleading manner.
In the first case – classified as unverified reviews – the trader marketed an “anti‑stress” product purported to stop panic attacks and anxiety. The website displayed positive testimonials that appeared with Bulgarian first and last names preceded by “@” (e.g. “@victordenkov”). The Commission found these reviews to be overtly promotional, portraying the product as a miracle remedy for anxiety, panic attacks, and depression – conditions typically requiring professional treatment.
The Commission concluded that, since no verification measures were in place, the trader could not ensure that the reviews reflected the experiences of real consumers.
The second case – classified as fake reviews – concerned a product marketed to improve vision. The Commission established that the reviews were artificially generated because identical testimonials appeared on mirror websites for the same product in North Macedonia and Croatia, with the reviewer names localised to traditional names in each jurisdiction (e.g. “Krasimir” in Bulgaria, “Mile” in North Macedonia, and “Mihovil” in Croatia). This cross-border duplication was treated as an objective indicator that the content was not genuine user feedback. The Commission therefore concluded that these reviews did not originate from real consumers who purchased or used the product.
In both cases, the Commission reaffirmed the principle that any review presented by a trader as information provided by a consumer must genuinely reflect the opinions, assessments, beliefs, or experiences of real consumers. The Commission found that the reviews in both cases created the overall impression that they originated from independent, impartial consumers and were therefore capable of influencing product presentation and ratings. As a result, the Commission found that these reviews could further influence and motivate the average consumer in their transactional decision to purchase the product.
The Commission appears to have taken the view that the identical reviews appearing under different names across various language versions of mirror websites constituted sufficient evidence of fabricated reviews. By contrast, where the origin of the reviews could not be established at all (even though they appeared fabricated for promotional purposes) the Commission classified the conduct as involving unverified reviews, focusing on the trader`s failure to implement reasonable verification measures rather than establishing an intent to produce fake reviews.
Whether the second case could also have been classified as involving fake reviews is debatable. The distinction applied by the Commission raises questions about the threshold for determining when a review is “fake” versus merely “unverified”, particularly where the practical effect on consumers is similar, but the evidentiary basis and the sanctions legal basis differ. Further decisions will show how the Commission’s practice develops and whether consistent criteria emerge to distinguish the two categories.
3. How did the cases reach the regulator?
Both proceedings were initiated by complaints. In one case, an individual consumer submitted screenshots and links to the relevant website. In the other, the Bulgarian Active Consumers Association, a member of international consumer networks, submitted a detailed, substantiated complaint.
In response, experts from the Directorate for Consumer Protection in Distance Selling – a specialised unit within the Consumer Protection Commission – conducted inspections. Notably, the unit has a team of 11 officials, responsible for nationwide online oversight and for enforcing the entire set of rules of the Consumer Protection Act in distance sales.
Taken together, the limited staffing and the complaint-driven nature of both cases suggest a primarily reactive approach to unlawful product-review practices on e-commerce websites. This illustrates that review enforcement is currently driven more by external signals than by systematic monitoring. Nevertheless, consumer NGO involvement may partly mitigate this by surfacing problematic practices to the Commission.
4. How did the regulator conduct the investigations?
First, the Commission sought information about the trader operating the online store. When this information was not available on the website (as required by Bulgarian law), the Commission reviewed the website’s technical details, including its domain registration, DNS records, IP address, and hosting provider.
During its investigation, the Commission made a test purchase via the website’s order form, with delivery by courier. The Commission then required information from the courier companies to identify the traders responsible for dispatching the goods.
To confirm the sender’s identity beyond doubt, the regulator requested a range of documents and information from the couriers, including a copy of the contract with the sender, the waybill, and payment records, such as cash‑on‑delivery receipts or IBANs used for bank transfers. Notably, in both cases the Commission also requested a comprehensive log of all parcels sent by the same sender during the previous 12 months, which enabled it to build a complete picture of the trader’s activity.
In both cases, the traders responsible for the misleading practices were registered in Bulgaria, although one of them operated via websites with a US-registered domain and hosting based in the Netherlands.
To confirm the operators’ identities beyond doubt, the Commission consulted the Bulgarian Commercial Register to ensure that the entities behind the online stores were correctly identified.
5. What are the consequences for businesses that breach consumer-review prohibitions?
Enforcement typically combines (i) an immediate prohibition order, (ii) a financial penalty, and potentially (iii) corrective publicity and follow-on consumer claims.
When the Consumer Protection Commission identifies misleading commercial practices involving consumer reviews, its primary response is to issue a prohibition order to stop the practice immediately. Under the Consumer Protection Act, these orders are the central remedy for addressing unfair commercial practices and are enforceable immediately even if the trader appeals; failure to comply with such an order is a separate offence that exposes legal entities to penalties, ranging from approximately EUR 1,000 to EUR 35,000.
In addition to the prohibition orders, the Commission may impose administrative penalty for the unfair practice itself, ranging from approximately EUR 1,000 to EUR 25,500.
Therefore, financial exposure typically arises in two ways: (a) fines for the unfair practice, and (b) separate penalties for breaching an enforceable prohibition order or other orders. Repeat infringements may result in the penalty being doubled.
A practical example of the Commission’s approach to setting fines is illustrated by the fake-reviews case, in which a fine of approximately EUR 2,000 – slightly above the minimum – was imposed for the unfair practice alongside the prohibition order and was subsequently upheld by the courts (Judgment No. 1669/05.05.2025 of the Sofia Regional Court under administrative-penalty case No. 15684/2024 and Judgment No. 34879/24.10.2025 of the Sofia Administrative Court under administrative case No. 6572/2025).
Furthermore, in case of misleading commercial practices, the Commission may require the trader or its advertising agency to publicise, at its expense, the prohibition order and a corrected advertisement. Although this corrective publicity has not been applied in the cases cited above, it remains a significant potential consequence for established brands.
Once a prohibition order becomes final, the legal pressure may shift to the consumer level, as consumers gain the right to demand price reductions, cancel their contracts, or claim damages.
Overall, this legal framework is designed to stop unlawful behaviour swiftly and creates substantial financial and reputational risks – making robust controls over consumer-review systems and due diligence essential.
