It comes up more often than you would expect. A new website is nearly ready, the testimonials section is empty, the launch date is not moving, and somebody suggests writing a few reviews to fill the gap. Nobody will know.
In Canada, that is not a marketing shortcut. Fake reviews are a false or misleading representation under the Competition Act, and the consequences attached to them are larger than most business owners realise.
What Canadian law actually says about fake reviews
The Competition Act covers misleading advertising twice over. Section 52 makes it a criminal offence to knowingly or recklessly make a materially false or misleading representation to the public to promote a product or a business interest. Section 74.01 reaches the same conduct through the civil route, where intent does not have to be proven at all.
A testimonial from a customer who does not exist is a representation about your business. So is a star rating assembled from reviews you wrote yourself. So is a “verified by” badge that nobody verified.
The amounts are the part that surprises people. Under section 74.1, a corporation can face an administrative monetary penalty of the greater of $10 million for a first order, three times the value of the benefit derived from the conduct, or — where that benefit cannot reasonably be determined — 3% of its annual worldwide gross revenues. A subsequent order raises the first figure to $15 million.
Those ceilings exist for the worst cases. The realistic exposure for a small Toronto business is different and closer to home: a complaint, an investigation, a consent agreement, and a permanent public record of it sitting where customers can find it.
2024 changed who can come after you
Until recently, enforcement of the deceptive marketing provisions ran almost entirely through the Competition Bureau. If the Bureau had bigger files open, a small operator with invented testimonials was unlikely to hear anything.
Bill C-59 received Royal Assent in June 2024 and amended the Act in several directions. The change that matters most to a small business is private access: since June 2025, parties other than the Bureau can apply to the Competition Tribunal over deceptive marketing practices.
In plain terms, your competitor can now act on your fake reviews. Competitors read your website more carefully than your customers do, and they have the motive the Bureau lacks.
The Competition Bureau is not your only audience
Google. Fake engagement breaches Google’s review policies outright. Reviews get removed, and a Business Profile can be suspended. That is not a fine you can budget for — it is your local visibility disappearing while you work through an appeal, and local search is where most of this traffic comes from.
Structured data. There is a quieter Google rule that catches honest businesses too. Reviews collected on your own site about your own business are treated as self-serving and are not eligible for star rich results. If your developer marked up a testimonials page with Review schema expecting stars in the search listing, they will not appear — and badly sourced markup can be flagged as spam.
The FTC, if you sell into the United States. The Federal Trade Commission’s rule on consumer reviews and testimonials took effect in October 2024. It prohibits fake and AI-generated reviews, buying positive or negative reviews, undisclosed insider reviews and the suppression of negative ones, and it carries civil penalties per violation. A Canadian business selling to American customers is inside its reach.
“But our reviews are real — we just copied them across”
This is the far more common situation, and it deserves to be separated from outright invention.
Plenty of sites display reviews that genuinely exist on Google, Houzz, Yelp or a supplier’s site, retyped by hand as website testimonials. The words are real. The problem is everything around them: the surname gets trimmed, the date disappears, the link to the source is dropped, and the three-star review quietly does not make the cut.
Once a reader cannot tell where a review came from or check it for themselves, a real review starts doing the same job as a fabricated one. Presenting only the favourable half while removing any way to verify it is where careful businesses drift into misleading territory without ever intending to.
It also ages badly. A retyped testimonial from 2019 sits on the page forever while your live rating moves on without it.
How to display reviews properly
- Pull reviews from the platform where they were left, through its API or an established widget, so the display updates when the source does
- Keep the reviewer’s name as they wrote it, the date and the star rating — and do not tidy up the wording
- Link to the source profile so a visitor can check for themselves
- Show the real average rather than a filtered selection. If it is 4.6, say 4.6
- Disclose any material connection — a discount, a free product, a staff or family relationship — next to the endorsement, not in a footer
- Leave AggregateRating markup to the platform that owns the reviews rather than generating star ratings out of your own testimonials
- If your real reviews are thin, ask for more. A short, specific request to recent customers works far better than anything you could write on their behalf
None of this is technically difficult. It only has to be decided before the testimonials section is built, because retrofitting it means rebuilding the block and often the schema underneath it.
The rest of the Canadian rulebook your website sits under
Reviews are the visible case. They are not the only place a Canadian website carries legal obligations, and a template build typically ignores every one of them.
- All-in pricing. Advertising a price that cannot actually be paid because obligatory fees are added later — drip pricing — is a deceptive marketing practice under the Competition Act. Booking forms and e-commerce checkouts are where this goes wrong most often
- Environmental claims. Since the 2024 amendments, claims about the environmental benefit of a product or a business must be supported by adequate and proper testing or a recognised methodology. “Eco-friendly” in a hero heading is a claim you now have to be able to back
- Accessibility. In Ontario, the public websites of organisations with 50 or more employees have been required to meet WCAG 2.0 Level AA under the AODA since January 2021. Very few themes meet it out of the box
- Email consent. A pre-ticked newsletter box, or a contact form that quietly adds people to a mailing list, is a CASL problem. Every commercial message also needs sender identification and a working unsubscribe
- Privacy. Contact forms, analytics, chat widgets and advertising pixels all collect personal information, which brings PIPEDA into play — a real privacy policy, meaningful consent, and a plan for breach notification. Quebec adds its own layer through Law 25 and French-language requirements for commerce in the province
Why this is an argument for hiring a Canadian developer
An offshore team working from a template will give you a fast, inexpensive website. What it will not give you is anybody who has read the Competition Act, knows what the AODA requires in Ontario, or understands why an all-in price matters on a booking form in Toronto but not in the market they usually build for.
These are not design decisions. They are decisions about which rules your business is operating under, and they get made by default — badly — every time somebody drops in a testimonials block or a pricing table without thinking about where the numbers and the names came from.
Working with a studio based here should mean all of the following are handled before you ever have to ask:
- Reviews wired to the platform they were left on, with names, dates and a link to the source
- Pricing components that show the total a customer will actually pay
- Accessibility built into the theme rather than bolted on after a complaint
- Forms, analytics and pixels configured with PIPEDA consent in mind
- Structured data that describes your business accurately instead of inventing ratings for it
- Somebody reachable in your time zone on the afternoon a claim on your site has to change
That last one matters more than it sounds. Compliance problems on a website are almost always urgent when they surface, and the difference between a developer you can reach and one you cannot is the difference between a correction made the same day and a claim sitting live for a fortnight.
The honest version usually converts better anyway
Fabricated testimonials read like fabricated testimonials. They are uniformly enthusiastic, vague about specifics, and written in one voice. Buyers who compare three quotes have seen hundreds of them.
Four real reviews that name a real problem and a real outcome do more work than twenty invented ones — and they are the only kind an AI assistant can safely repeat when somebody asks it who to hire.
Not sure what your current site is claiming on your behalf? We review testimonials, pricing displays, forms and structured data on websites across the Greater Toronto Area and flag what needs to change. No automated report, no sales pressure. Talk to a Toronto WordPress developer →
Frequently Asked Questions
This article explains how these rules work in practice for website owners. It is not legal advice. If you are already facing a complaint, speak to a lawyer.
Yes. Inventing customer reviews or testimonials is a false or misleading representation under the Competition Act. Section 52 makes it a criminal offence to knowingly or recklessly make a materially false or misleading representation to promote a business, and section 74.01 covers the same conduct civilly, where intent does not have to be proven. Since June 2025, parties other than the Competition Bureau – including competitors – can also bring applications to the Competition Tribunal over deceptive marketing.
Publishing an endorsement the customer genuinely gave is fine. Writing the words yourself and attributing them to a named customer is a representation about what that person said, and it is misleading even with their permission. Ask for the review in their own words instead, and disclose any material connection – a discount, a free product, a staff or family relationship – wherever the endorsement appears.
You control what appears on your own site, but selectively removing unfavourable reviews while presenting the remainder as a rating is where this becomes misleading. On Google, Yelp or a similar platform you cannot delete reviews at all. You can respond to them, and you can report ones that breach the platform’s content policy.
The Competition Act’s deceptive marketing provisions apply regardless of company size. Some other obligations do have thresholds – Ontario’s AODA web accessibility requirement applies to organisations with 50 or more employees – but nothing about being small exempts a website from the rules on misleading claims.
Under section 74.1 of the Competition Act, a corporation can face an administrative monetary penalty of the greater of $10 million for a first order, three times the value of the benefit derived from the conduct, or – where that benefit cannot reasonably be determined – 3% of annual worldwide gross revenues. A subsequent order raises the first figure to $15 million. For individuals the figures are $750,000 and $1 million. Those ceilings are for the most serious cases; the realistic exposure for a small business is an investigation, a consent agreement and a public record of it.
If your site collects personal information – a contact form, a booking widget, a live chat, analytics or advertising pixels – then PIPEDA applies and you need a genuine privacy policy and meaningful consent, not a copied template. Businesses handling personal information in Quebec have additional obligations under Law 25.
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