Before you pay for reviews, read the rules that apply.

This is the law, and it is the rule that carries fines. Section 21 empowers the Central Consumer Protection Authority to act on a false or misleading advertisement, and it names two categories of person: the manufacturer and the endorser.

“(2) ...if the Central Authority is of the opinion that it is necessary to impose a penalty in respect of such false or misleading advertisement, by a manufacturer or an endorser, it may, by order, impose on manufacturer or endorser a penalty which may extend to ten lakh rupees: Provided that the Central Authority may, for every subsequent contravention by a manufacturer or endorser, impose a penalty, which may extend to fifty lakh rupees.”

There is also a non-monetary remedy aimed squarely at the person who did the endorsing:

“(3) ...it may, by order, prohibit the endorser of a false or misleading advertisement from making endorsement of any product or service for a period which may extend to one year”

Two things to read carefully. These are civil penalties for a contravention, not criminal convictions. And they attach to a manufacturer or an endorser, not to any party generally.

The due-diligence defense in section 21(5)

If you pay creators to create content about your product, this is the sentence in the Act to know, and summaries often leave it out:

“No endorser shall be liable to a penalty under sub-sections (2) and (3) if he has exercised due diligence to verify the veracity of the claims made in the advertisement regarding the product or service being endorsed by him.”

So an endorser who checked the claim has a defense. That is a good reason to work with people who have actually bought and used the product, and to keep the claims in your brief to things they can check.

Its full title is Online Consumer Reviews: Principles and Requirements for their Collection, Moderation and Publication, notified on 23 November 2022. The first thing to know is its status, which the government states plainly:

“The standards are voluntary and are applicable to every online platform which publishes consumer reviews. The guiding principles of the standard are integrity, accuracy, privacy, security, transparency, accessibility and responsiveness.”

The second thing is where most write-ups get it wrong. The standard does not ban rewarded reviews outright. What it bans is a specific thing: reviews bought or written to order:

“The review administrator shall not knowingly publish reviews that have been purchased and/or written by individuals employed for that purpose by the supplier/seller, or by a third party.”

And then, in the very next clause, it expressly contemplates a reward:

“The review administrator may offer the review author a reward for their review of a product or service, whether this review is unsolicited or solicited.”

It attaches four conditions to that, and they are the whole point of the clause:

“a) The reward shall not depend on the content of the review submitted (for example a reward should be given whether the review was positive or negative); b) The review administrator shall specify the nature of the opportunity to receive a reward in the terms and conditions; c) Rewards can be given before or after a review is submitted; and d) The review administrator shall clearly display a 'mark' alongside the review to make readers aware that a reward was offered for the review.”

Note who it binds. Clause 5.6.2 addresses the review administrator, the platform that collects and publishes the reviews. It isn’t a permission granted to a seller, and it isn’t a permission granted to a platform like ours. So the correct conclusion is narrow but important: even the Indian standard that allows a reward for a review requires that the reward be independent of what the review says, be disclosed in the terms, and be marked visibly alongside the review so readers know.

Amazon, as the review administrator on its own marketplace, offers no such mechanism to sellers. There is no “rewarded review” badge you can opt a paid review into, and its own guidelines prohibit compensated reviews outright. So a seller can’t buy reviews on a marketplace and stay within the rules. Rewards aren’t forbidden in India as such; the only party who could offer a compliant one is the platform, and Amazon has chosen not to. Vine is the exception: Amazon runs it, and every Vine review carries a visible badge.

Issued under the same Act, and aimed at deceptive interface and content practices:

“The Central Consumer Protection Authority, in exercise of the powers conferred by Section 18 of the Consumer Protection Act, 2019, has issued 'Guidelines for Prevention and Regulation of Dark Patterns, 2023' on 30th November, 2023 for prevention and regulation of dark patterns listing 13 specified dark patterns.”

What makes them enforceable is how they are classified:

“Such practices fall under the category of 'unfair trade practices' as defined under the Consumer Protection Act, 2019.”

An advisory issued in early June 2025 asked e-commerce platforms to look for these practices themselves:

“All e-commerce platforms have been advised to conduct self-audits to identify dark patterns, within 3 months of the issue of the advisory”

And by late 2025 the Ministry was reporting the result:

“26 leading e-commerce platforms have voluntarily submitted self-declaration letters confirming compliance with the Guidelines for Prevention and Regulation of Dark Patterns, 2023.”

ASCI is a self-regulatory body rather than a statutory regulator, so its code isn’t law. Its trigger is wider than payment: it is anything of value.

“Material connection is not limited to monetary compensation. Disclosure is required if there is anything of value given to mention or talk about the advertiser's product or service.”

The guidelines never mention follower counts. Our reading is that the trigger is the material connection, not audience size. And the label has to be visible:

“Disclosure must be upfront and prominent so that it is not missed by an average consumer.”

ASCI’s own monitoring reports that 76% of the top 100 digital stars failed to meet disclosure norms, against 69% the previous year, across posts published between 1 March and 15 July 2025. It is the rule you can most easily control yourself: check the label before you approve a piece of content.

Amazon’s Community Guidelines don’t allow a review “in exchange for any compensation”, and its Anti-Manipulation Policy says it may suspend or terminate Amazon privileges, remove reviews, delist related products and withhold or forfeit payments. Flipkart publishes its own seller policy, which this page doesn’t quote: read it at the source.

A marketplace needs no court to enforce this, so a plan has to pass its policy as well as the law.

One more number, and what it is: a LocalCircles survey, May 2024, n>54,000, a self-selecting online consumer panel, not a regulator’s finding and not a controlled study, so treat the number as indicative rather than precise:

“60% of eCommerce users surveyed say they have found reviews on eCommerce sites/ apps to be positively biased”