Legal Q&A · IT, Software & E-commerce

Do we have to verify reviews on our online shop?

Law as at 29 August 2026

Answered by , Czech and Slovak attorney, admitted to the Slovak and Czech Bars (SAK 300422 · ČAK 19654).

Short answer

You do not have to verify reviews: the duty is to provide information. If you display reviews, explain whether and how you ensure they come from real customers. If you do not verify them, say so. Truthfulness is the boundary: labelling reviews as verified without real checks, or publishing commissioned fake reviews, is an unfair commercial practice. The same principle applies in Slovakia and Czechia.

Must you investigate who wrote every review? No. The law lets you choose whether to verify reviews, but requires customers to know where they stand. The problem lies in pretending reviews are verified.

The duty is to provide information

Slovak Act No. 108/2024 Coll. treats review verification information as material information whose concealment is a misleading omission:

Material information under paragraphs 1 and 2 also includes information on (a) whether and how the trader ensures that product reviews originate from consumers who actually bought or used the product, where the trader gives consumers access to product reviews.

— Section 11(6)(a) of Act No. 108/2024 Coll. (unofficial English translation)

If you do not verify reviews, say so. If you do, explain how, for example by allowing reviews only from customers with completed orders. Place the information where reviews appear: material information hidden or presented inappropriately is a misleading omission just like withheld information (Section 11(2)). Czech interpretative practice reaches the same conclusion, as explained below.

Where the unfair-practice boundary lies

Annex 1 to Act No. 108/2024 Coll. lists practices always considered unfair (Section 9(5)). These include claiming reviews come from actual customers without taking reasonable verification steps, publishing or commissioning fake reviews, and misrepresenting reviews. A “verified reviews” label without a functioning mechanism is therefore prohibited in all circumstances. Deleting negative reviews while retaining positive ones falls into the same category because the resulting picture is no longer truthful.

This also matters during inspections: when the Slovak Trade Inspection checks an online shop remotely, it takes screenshots of the review-policy page too, as illustrated in SOI inspections based on screenshots.

The position in Czechia

The Czech rules mirror this: under Section 5a(5) of Act No. 634/1992 Coll., information on whether and how the seller ensures published reviews come from actual customers is material information. The Czech Trade Inspection’s “Reviews” FAQ on coi.gov.cz adds practical details: the amendment introduced no duty to verify; information must appear directly beside published reviews, as terms and conditions alone are insufficient; older reviews may remain, but their verification status must also be stated; verified and unverified reviews may be mixed if clearly distinguished; and a review of a product supplied free for testing must be labelled sponsored. Fake reviews are also always prohibited in Czechia: the Inspection refers to points (y) and (z) of Annex 1 to the Czech Consumer Protection Act.

If you sell in both countries, one honest verification process and one explanation beside reviews can cover both jurisdictions. Differences concern supervisory details rather than the principle.

How we can help

We configure review collection and verification wording through our online shop terms service. Our influencer agreement covers paid partnerships and products supplied for testing, including required labels. If a supervisory authority challenges your reviews or labels, our e-commerce legal services prepare the response.

Before adding a “verified purchase” label, have its underlying process checked: that label is precisely what the authority compares with reality.

This answer provides general information on the law as at 29 August 2026. It does not constitute legal services or replace an assessment of an individual case. The details of your situation may differ. Book a consultation to discuss them.

More legal questions

All questions and answers
  1. The supplier of our new system will be migrating our customer data. Do we need a GDPR contract with it? Yes, where the supplier handles personal data of customers or employees on your behalf during migration, testing or support. It is then a processor, and the processing must be governed by a contract with the content prescribed by Article 28 GDPR, in writing, including in electronic form. Among other things, the contract must provide that the supplier processes the data only on your documented instructions and that it returns or deletes the data once the services end. The duty to select a supplier offering sufficient guarantees rests with you as controller.
  2. A trademark owner is demanding that we hand over our domain. Must we? Not automatically. A trademark owner may prohibit the use in the course of trade of an identical sign for identical goods and services, and of a similar sign where there is a likelihood of confusion, but not to the detriment of rights acquired before its application was filed. In alternative dispute resolution for a .sk domain it is also examined whether you have a right or legitimate interest in the domain and whether you acquired and used it in good faith. Do not ignore the demand, but nor should you comply with it before checking your position.
  3. We are buying an e-shop. How do we make sure the domain passes to us as well? It depends on whether you are buying the company or its business, and on who is actually registered as the holder of the domain. On a purchase of an ownership interest, the domain remains with the company if the company is its holder. On a purchase of the business, the rights covered by the sale pass to the buyer, but the domain registry will record a change of holder only on an application by the existing holder, made through a registrar and with the consent of the new holder. The contract must therefore oblige the seller to take that step, and payment must be tied to it.
  4. Our client is not supplying materials or testing during software development. Must we still meet the deadline? While you are waiting for cooperation the client owes under the contract, it is the client, not you, who is in delay. The Commercial Code states expressly that a debtor is not in delay where it cannot perform as a result of the creditor's delay, and a client who fails to provide the necessary cooperation is a creditor in delay. If the client fails to provide that cooperation even within an additional reasonable period, you may withdraw from the contract and claim the price reduced by what you have saved. What matters, therefore, is whether the cooperation is identified in the contract and whether you are notifying its absence in a demonstrable way.

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Mgr. Patrik Tulinský, LL.M. Czech and Slovak attorney · SAK 300422 · ČAK 19654

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