DDL PMI, stop to false reviews: new rules in force but without AGCM guidelines
Starting from April 7, 2026, Law No. 34 of March 11, 2026, also known as the DDL PMI, dedicated its Chapter IV to combatting false online reviews. This regulation, long awaited by the tourism and catering industry, introduces precise criteria for the legality of comments published on digital platforms but comes into effect without the necessary application guidelines, which are still being developed by the Antitrust Authority.
What Makes a Review Legal
Fundamental is Article 19: a review must be published within 30 days of the actual use of the product or service and must come from someone who has personally used it. Generic experiences are not sufficient; the law introduces a presumption of authenticity for reviews accompanied by fiscal documentation: that is, a receipt, invoice, or equivalent. Reviews written in exchange for discounts, freebies, or any form of incentive from the provider are illegal, as are those marked as "verified" without the reviewer having actually used the service.
The regulation also sets a sort of expiration: after two years from publication, a review loses its legality as it is no longer current, unless the business concerned can demonstrate that it has adopted corrective measures. The legal representative of the reviewed establishment can report content deemed illegal to the managers of the online platforms and request its removal, in line with the provisions of the Digital Services Act.
The Prohibition of Buying and Selling Reviews
Article 20 introduces an explicit and generalized ban on the purchase, sale, or transfer of online reviews, comments, and interactions, regardless of their subsequent dissemination. These measures aim to bring the market for fake reviews into the crosshairs of the AGCM. The focus is primarily on combating the phenomenon where brokers construct networks of users willing to publish five-star comments in exchange for refunds or free products. The authority also gains investigative and sanctioning powers under Article 27 of the Consumer Code. Sanctions may also apply to search engines if they do not monitor their algorithms adequately.
The provisions apply exclusively to reviews published from April 7, 2026, onwards and pertain to products, services, and offerings provided by businesses in the catering and tourism sectors located in Italy. Thus, it is not a universal regulation: all other e-commerce sectors remain outside its scope. It is worth noting that similar phenomena have already led to exemplary measures in the world of platforms: Trustpilot came under the Antitrust Authority's scrutiny for guided review practices, a case that highlighted the urgency for a structured regulatory framework.
The Issue of Guidelines
The critical point is that the law comes into effect today without the AGCM having yet published the application guidelines envisaged by Article 21. The time needed for their development may not be short, which would create an operational gap precisely at the launch phase. According to data from Codacons, about 77% of Italian consumers consult online reviews before purchasing a product or booking a service: without clear guidelines, there is a risk that the new rules remain more on paper than in practice.
Some legal experts have already raised doubts about the practical applicability of certain provisions, particularly regarding the verification mechanism through fiscal documentation and potential conflicts with European legislation. The FIPE, federation of public establishments, has welcomed the law as a “first step” towards greater transparency in the digital reputation of businesses, while acknowledging that much will depend on its actual implementation.