This article is an update to our original, 'Review Gating - The Devil's Bargain of Online Reputation Management' published in September 2025. A lot has changed and many of the things that I cautioned would happen are now happening in real time. If you read the original and thought the risk was manageable, it is time to pull your head out of the sand.
Back in September 2025, I wrote about the Google review gating, the practice of filtering customers through a satisfaction screening process before directing them to leave a Google review; sending the happy ones to Google and quietly redirecting the not so positive ones or burying them somewhere they will never be seen or impact your review score.
I closed that article with a Warren Buffett line: 'When the tide goes out, you discover who has been swimming naked'.
Well it now looks like the tide is ebbing fast.
Review gating (or to call it what it really is review manipulation) is not a particularly niche practice confined to shady fly-by-night operators. You’ve likely been review gated at least once in the last year or two (I have including every time I go the dentist) and I have sat in many meetings where review gating is actively being sold as a legitimate product and a reputational ‘silver bullet’ for glossing over poor customer experiences.
It is widespread across New Zealand dental and medical clinics, trades businesses, hospitality venues, real estate agencies and franchise networks; sectors where a cluster of poor reviews can seriously damage new customer acquisition and revenue. But here’s the thing: most of the business owners using this software have no idea they are in breach of Google's policies or the Fair Trading Act and can be dragged through the courts and penalised out of existence for doing this.
What Has Changed Since September 2025
The short version: Google's enforcement has gone from a known risk to an active, AI-powered reality. But more significantly for New Zealand businesses, review manipulation is no longer just a platform policy issue. It is a legal one and the Commerce Commission has made it an enforcement priority.
Here is what has happened since the original article was published.
Google's enforcement has dramatically escalated. Between January and July 2025, Google's review deletion rates increased over 600%, with nearly 2% of all monitored business locations experiencing at least one review deletion per week at peak enforcement. Approximately 38% of the reviews targeted were 5-star reviews. This was not a glitch. It is a systematic shift in how Google polices its review platform.
I covered this in my last article but for the avoidance of any doubt, the benefits of review gating are often minimal for all but the very worst and poorly-reviewed business operators, but the costs can be catastrophic. If your review profile is found to have gated reviews, Google may go as far as removing all of your reviews, not just the ones it suspects of being gated. Your deceptive business practices and false customer review scores could be exposed and you could end up being prosecuted to the tune of hundreds of thousands of dollars by the NZ Commerce Commission for breaches of the Fair Trading Act 1986 and having your brand and reputation destroyed.
The NZ Legal Dimension: Fair Trading Act 1986
This is the part that every NZ business currently using or considering a review gating solution needs to read carefully.
Review manipulation in New Zealand is not only a Google policy issue. It is a potential legal liability under the Fair Trading Act 1986, which prohibits misleading or deceptive conduct. The Commerce Commission has prosecuted businesses for exactly this type of behaviour and applied very significant penalties.
The TV Shop (December 2025)
Several high-profile cases have seen the NZ Commerce Commission take punitive action against companies engaged in review manipulation. At the end of last year, The TV Shop, the company behind several well-known brands including Thin Lizzy was convicted on 13 charges for breaches of the Fair Trading Act.
The court found that TV Shop staff members posted reviews on various online review platforms without disclosing their affiliation to the business, at their request and sometimes for a reward. Commerce Commission Deputy Chair Anne Callinan, speaking of consumers stated: "They should also be able to trust that genuine customer reviews are not excluded in order to positively skew product ratings."
The penalty hearing date has not yet been set. Under the current Fair Trading Act, the maximum penalty is $200,000 per provision. Across 13 charges, the exposure is significant. The timing also matters: if the penalty hearing runs into late 2026 it could potentially fall under the new incoming policy (where the maximum penalty for corporates rises to NZ$5 million!).
The Commerce Commission has published guidance to assist businesses to meet their legal obligations when they collect or publish customer reviews which is a useful resource for any businesses that wants to audit their current practices.
Bachcare (December 2019)
Bachcare was fined $117,000 after pleading guilty to two counts of breaching the Fair Trading Act. The company had withheld customer reviews with a star rating below 3.5, with the offending extending to 22% of its listed properties and 3.4% of all reviews on the platform. The presiding judge noted that the case only came to light only because a single consumer noticed their review had been edited.
The Bachcare case is particularly instructive because the mechanism used i.e withholding reviews below a satisfaction threshold is by design exactly what review gating software does. The label is different. The legal exposure is the same.
New Zealand's Penalty Ceiling is About to Rise Sharply
If you needed any further convincing on the costs versus benefits of manipulating your reviews rather than improving your scores by providing a better service or product, this will surely tip you over the edge.
Penalties for breaching most Fair Trading Act provisions, including misleading and deceptive practices, will increase to the greater of $1 million for individuals or $5 million for body corporates, or three times the value of the commercial gain made. Legislation is to be introduced to Parliament in the first half of 2026, with the changes expected to become law later in 2026.
The Commerce Commission itself has welcomed the change, noting that fines had become little more than a "cost of doing business" for some and that when misleading conduct leads to profits that outweigh the penalties, that is a problem.
The Google Penguin Parallel (This Has All Happened Before)
I have been working in digital marketing long enough to remember the Google Penguin algorithm update in April 2012. It was designed to target businesses that had been artificially inflating their search rankings through prohibited link building tactics, a practice that had been widespread and had gone very largely unpunished for years.
When Penguin rolled out, it affected 11.8% of all search queries overnight. Websites that had been gaming the algorithm for years including well established, revenue-generating businesses lost between 50% and 90% of their organic search traffic within days. The worst-affected sites lost up to 91% of their search visibility. Of the twenty hardest-hit websites, only two ever made any meaningful recovery. Most never came back.
Google has a well-established track record in these areas. No special warning. No consultation. No opportunity to clean up your act. Just enforcement from above, and a gruelling, bureaucratic recovery process that can take years, if recovery is possible at all.
The companies that had been pushing the services to clients and agencies stopped taking their clients' calls the same day enforcement hit in true fly-by-night operator fashion. I suspect a lot of them were just busy rebranding and trying to price and rollout their new backlink-penalty recovery and remediation services to answers the phones.
To my eyes, review gating shares a lot of the same hallmarks as the SEO linking building hay day pre-collapse and is the same thing just playing out in a different channel. The enforcement is already underway. The question is whether your business will find itself in the crosshairs.
The Real-World Consequences Are Already Here
This is no longer theoretical. Businesses across multiple sectors have reported catastrophic review losses through 2025 and into 2026.
Healthcare operators have reported losing large volumes of reviews, while local service businesses have reported that despite running over 200 jobs and requesting reviews on all of them, not a single new review was appearing. Restaurant owners have reported losing reviews going back four years in a single enforcement sweep.
Looking overseas, The US's FTC fined Fashion Nova $4.2 million for blocking negative reviews a clear example that what begins as a platform policy violation can escalate into regulatory and legal action and gives us a possible glimpse of what may be to come as the ripples reach New Zealand shores.
What You Should Be Doing Instead
The good news is that building a genuine review profile is neither complicated or slow when done properly. Here is what compliance looks like in 2026.
1. Ask every customer, not just the happy ones.
This is non-negotiable. Google's policy explicitly prohibits selectively soliciting positive reviews. Ask everyone. A business with 4.4 stars from 200 genuine reviews is more credible and infinitely less exposed than 4.9 stars from 40 gated reviews.
Research from the Spiegel Research Center at Northwestern University found that purchase likelihood peaks in the 4.2 to 4.7 star range before dropping off as scores approach 5.0. A near-perfect score can actually reduce consumer trust as it looks implausible. Many consumers know that reviews can be skewed (even if they are not quite sure how) and they know when they can smell something fishy.
2. Send review requests after the customer interaction has taken place.
Do not ask for reviews while the customer is still on your premises. Give them time to reflect and make the request feel natural rather than pressured, if using automated systems, try and personalise this as much as possible e.g first name personalisation and referencing the branch location etc.
3. Keep internal feedback separate from public review requests.
You can run an internal Net Promoter Score (NPS) or satisfaction survey but keep it clearly separate from your Google review request. The moment you use the survey results to decide whether to send someone a review link, you have crossed into gating territory.
4. Do not give guidance on what customers should say.
Instructing reviewers to mention specific staff members, services, or keywords is a policy violation. Send the link and let them write what they experienced in their own words.
5. Do not offer customers incentives.
No discounts, no freebies, nothing conditional on leaving a review. Google's AI is now specifically calibrated to detect the patterns that incentivised review campaigns produce.
6. Respond to every review, including the negative ones.
A business with a thoughtful response to a critical review signals authenticity to Google and to prospective customers. When I am using reviews to help evaluate a service provider, I actively go looking for the bad reviews as things can of course go wrong from time to time and I like to see how the business handled this and resolved it. Handled well, a negative review can be turned into an asset and unhappy customers can be turned into some of your strongest advocates (but definitely not all of them).
7. If competitors are gating reviews, you can report them.
There are a number of ways to do this, ranging from contacting them directly to tell them that they are cheating and to stop before "someone" reports them (you can share this article if you like), reporting them to Google directly (just document their review gating process accurately). You can even make a Commerce Commission complaint at comcom.govt.nz/make-a-complaint. The Bachcare case was triggered by a single consumer noticing an edited review. One documented complaint can be sufficient to open a Commission investigation.
The Only Strategy That Works Long Term
The businesses that come out of this enforcement period strongest will be the ones that have been doing it properly all along, delivering good work, asking all customers for honest feedback, and responding professionally to everything they receive. Remember, a review score of 4.2 to 4.7 is the sweet spot and if everyone had 5 star reviews then there would be absolutely no point in having review scores at all.
Most of the best businesses we have worked with over the years take their reviews and their review scores extremely seriously and for very good reason too. What I believe separates these businesses from the not-so-hot ones is that they treat review feeds as an important customer feedback tool; an opportunity to learn and improve their operations. They don’t view suggestions from their customers as something to be suppressed and hidden from other potential customers and they actively work to try and remedy any issues that have genuinely gone wrong and are seen to be doing this.
As business owners and especially as marketers we should not forget the Latin phrase “The voice of the people is the voice of God” (Vox populi, vox Dei).
The gating shortcut was always going to be a long ride for a short slide and for the businesses that took it, the bill might be just about to fall due.
Ronan Nichol is the founder of Storm IMC, a full-service digital marketing agency based in Auckland. Storm IMC works with New Zealand businesses on online reputation management paid search, SEO, digital advertising, social media and AI-driven marketing automation.
