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Collecting Customer Reviews Without Breaking the Rules

How small firms earn genuine customer reviews: the right moment, the personal request, short paths via QR code and the limits set by competition law.

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A business can do careful, clean work and still look, online, like someone nobody has anything to say about. The reason is rarely dissatisfaction — it is inertia. People who are happy think about many things after the final handshake, and a review form is not one of them. The German Federal Cartel Office (Bundeskartellamt), in its sector inquiry into user reviews, puts the share of users who leave a review at all at around 1 percent (Bundeskartellamt), citing a one percent rule described by market participants, and names the effort involved as the main reason people do not write reviews (Bundeskartellamt). So if you want reviews, you have to ask. And that is exactly where the legal part begins, because two sentences can separate a permissible request from an influence that gets you into trouble. This article describes the road to genuine reviews: the right moment, the form of the request, short paths via link and QR code, clear ownership in the team, realistic expectations about response rates, and the lines drawn by competition law.

Collecting reviews the right wayAsking, short paths, clear ownership — and the limits set by competition lawAnnex to Section 3(3) UWGThree short pathsone tap or one scan, no searchingInvoice and delivery noteQR code next to the payment detailsVehicle and foldersticker, card, at the handoverCounter and receptionsmall card with request and QR codePractice example from the BundeskartellamtYour own review pageshort address, clear instructionsInstructions in three linesLinks to your profilesNotice on verificationyour-company.com/reviewsThe QR code points to this exact addressNo reward, no pre-selectionWho leaves a reviewshare of customers ratingGeneral1%Energy5%Hotels14.5%Bundeskartellamt sector inquiryThe one percent rule applies without askingAsking raises the response rateLimits set by competition lawNo rewarddiscounts, vouchers or a free drinkin exchange for a reviewNo pre-selectionshow every response, not onlythe friendly onesNo self-written textsneither written yourself norcommissioned from othersNo praise from the teamreviews from inside the firm arenot customer voices

Why asking makes the difference

Reviews rarely appear on their own. For its sector inquiry, launched in May 2019, the Bundeskartellamt contacted 66 portals (Bundeskartellamt), received answers from 62 portals (Bundeskartellamt) and evaluated 67 questionnaires (Bundeskartellamt). One finding from that data set is immediately practical for any local business: the share of customers who actually write a review usually sits in the low single-digit percentage range (Bundeskartellamt). It varies by sector — on energy comparison portals roughly 5 percent (Bundeskartellamt) of customers leave a review, on hotel comparison portals 14.5 percent (Bundeskartellamt).

The second finding matters even more. People review when an experience carried strong emotion. Market participants consistently told the Bundeskartellamt that extreme experiences are the trigger: you write a review when you are particularly pleased or particularly annoyed, while the large majority of perfectly ordinary experiences barely show up in reviews at all (Bundeskartellamt). For a business that means: if you do not ask, you get the outliers. The satisfied regular who has had the annual service done for four springs running writes very little unprompted. The one irritated caller writes immediately.

Without a request you hear the edges, not the middle

The star distribution confirms the picture. Across all portals examined, more than 80 percent (Bundeskartellamt) of the displayed reviews carry four or five stars, while one-star reviews account for only 6 to 7 percent (Bundeskartellamt). That is not a reason to relax; it shows how strongly the public picture depends on a handful of voices. Asking regularly and evenly broadens the base — and makes the result less vulnerable to single outliers.

The reader side shows why the effort pays off. In the survey evaluated by the Bundeskartellamt, 56 percent (Bitkom) of respondents said they use reviews as a decision aid. And according to the studies reviewed, offerings with no reviews at all are chosen less often than offerings that carry even a few negative ones (Bundeskartellamt). An empty review section is therefore worse than a mixed one. How the collected voices then land on your own site in a legally sound way is covered in detail in the article on showing customer reviews correctly.

The right moment: straight after completion

The best moment to ask is the one in which the work has just been experienced and still feels good: handing over the finished job, settling the bill after a pleasant evening in the restaurant, the moment after treatment when the relief is visible. After that, recollection drops away fast. Send an email two weeks later and you are competing with everything that has happened since. The sector inquiry supports this indirectly: more reviews are submitted when users have time — one online retailer reported that Sundays bring the most and Tuesdays the fewest reviews (Bundeskartellamt).

At the handover

The work has been accepted, the customer is happy, you are still standing side by side. One sentence is enough: „If you were happy with the work, a short note online would help us a lot — the slip is with the invoice." No sales pitch, no explanation of the benefit.

The following day

If the appointment left no opening, the next day is the second-best choice. The memory is fresh and everyday life has not yet written over the impression. Later than a week after completion, the likelihood of a response drops noticeably (project experience).

After the first result

For work whose effect only shows later, completion is the wrong moment. A new heating system is judged after the first cold week, insulation after the first bill. Here a follow-up with some distance works better — with reference to the concrete outcome.

Who tends to answer is also worth knowing. When users are asked by email to leave a review, the response rate is higher among women than among men, and higher among older people than among younger ones (Bundeskartellamt). For a business with a mixed customer base the lesson is simple: do not rely on one channel. Asking only by email leaves part of your customers unreached — which is why the printed path belongs alongside the email, and the spoken word alongside the printed path.

A time window, not a barrage

According to the sector inquiry, some review portals prompt users up to four times to submit a review (Bundeskartellamt). For a trade business or a practice that is the wrong benchmark. A sensible pattern: ask once in person, send one friendly reminder, then let the matter rest. Following up more often creates pressure — and pressure is exactly what turns a free opinion into an influenced review.

The personal request beats the bulk email

The biggest difference in response rate comes from the relationship, not the tool. A serial email sent automatically to every customer of the quarter reads like advertising and gets treated accordingly. A request voiced by the fitter who has just spent three hours in the house is a personal favour — and it is granted far more often. That matches the motivation the Bundeskartellamt describes from the studies it evaluated: people who write reviews mainly want to help other users, express their feelings or give the provider feedback (Bundeskartellamt).

AspectBulk email to everyonePersonal request at the end of the job
SenderA company address, often with no reply option and no face attachedThe person the customer has just been dealing with, by name
ReferenceGeneric: „How satisfied were you with us?"Specific: „How happy are you with the new bathroom?"
Perceived effortFeels like a task to do later, and later becomes forgottenFeels like a small favour that is done straight away
Typical effectLow response rate, many deletions before readingClearly higher response from a smaller base (project experience)

Wording matters too. Sentences such as „Your review helps us grow" put the benefit on the business. It works better to point out that the feedback helps other people with the same problem — which is what actually motivates reviewers according to the studies evaluated (Bundeskartellamt). How to phrase such sentences more plainly and less promotionally in general is covered in the article on writing website copy customers actually read.

  • „If you were happy with the work, would you write that down online? It helps others with the same problem." — names the benefit for third parties rather than for the business
  • „Two sentences are plenty, it does not have to be an essay." — lowers the hurdle that the sector inquiry identifies as the main reason people do not review (Bundeskartellamt)
  • „If something did not fit, please tell us that too — online or directly, whichever you prefer." — keeps the path for criticism open instead of diverting it
  • „The QR code is at the bottom of the invoice." — points to the short path instead of triggering a search
  • Without additions such as „for a good review", „for five stars" or the promise of anything in return

Review requests by email count as advertising

An email asking for a review serves sales promotion and therefore counts as advertising. Without explicit consent it is permitted only under the narrow conditions of Section 7(3) UWG — an existing customer relationship, similar goods or services of your own, and an option to object both at collection and in every message. If you collected the address for invoicing anyway, include the objection notice. What else to observe around consent is set out in the article on GDPR and cookie consent.

Short paths: link, QR code, invoice, vehicle, counter

According to the sector inquiry, the main reason people do not review is, across every area examined, simply the effort involved (Bundeskartellamt). Every step you remove raises the response: searching for the business, creating an account, finding the right entry among three similar ones. That is precisely why physical nudges work. The Bundeskartellamt explicitly describes the example of cards asking for a review, complete with a QR code, placed at the reception desk of medical practices (Bundeskartellamt).

Invoice and delivery note

A small QR code next to the payment details, plus one sentence. The invoice gets read anyway, usually at a desk with a phone within reach. That is the channel with the highest attention and the lowest extra cost.

Vehicle and handover folder

A sticker on the tailgate, a card in the folder with the paperwork, a tag on the key ring. These paths keep working beyond the job itself, because the vehicle is seen by neighbours and passers-by as well.

Counter, bar and reception

A small stand next to the till, a card with the bill, a sign by the coat rack. In hospitality and retail the second after payment decides it — after that the guest is outside and the impulse has gone.

A QR code lands on a phone in practically every case. The target page therefore has to work on small screens: large tap targets, quick loading, no intermediate steps. What that requires is described in the article on mobile usability for business websites. A code that leads to a slow or confusing page costs you the review you have just asked for.

  • The target address is short and free of special characters, so it can be typed if the code fails to scan
  • The path from scan to submission covers no more than two screens
  • The page states where a review can be left — with one clearly labelled link per portal on which the business is actually listed
  • There is a second path for criticism that is not meant to be public, visible with equal weight
  • The notice on whether and how authenticity is checked sits on the same page
  • The code works in print from roughly two centimetres across and has enough contrast against its background
  • The address stays the same even when portals change — what changes then is only the page behind it

Clear ownership instead of good intentions

The most common pattern in small firms: everyone agrees to ask for reviews from now on, it works for three weeks, then the busy season arrives. Without a named owner the topic disappears. What helps is a split in which nobody has to do everything, and in which the task is tied to an existing step in the workflow rather than to a good intention.

  1. Asking: the person with customer contact at the end of the job. They voice the request without explaining or justifying it.
  2. Reminding: the office, tied to sending the invoice. One sentence and the link belong in the standard invoice text, not in an extra task.
  3. Watching: one fixed person checks the profiles weekly and enters new reviews in a simple list — date, portal, tone, open or answered.
  4. Answering: the owner, especially in the case of criticism. Replies to negative reviews should not be delegated by whoever carries the responsibility.
  5. Checking: once a quarter, a look at whether the details on the review page still hold and whether the verification notice describes actual practice.

Together these five points cost less than an hour a month once they hang off existing routines. They belong in the same cycle as opening hours, prices and contact details — which maintenance steps make sense at which intervals is described in the article on website maintenance for small firms.

One line in the handover

Add the request to the checklist that already gets worked through at the end of every job — right next to „work area swept" and „documents handed over". That turns an idea into a step. The handling in daily practice matters: you ask regardless of how the job went. Asking only where customers look visibly pleased is already a pre-selection — and pre-selection is where competition law gets uncomfortable.

What realistically comes back

Managing expectations saves frustration. Without a request, the share of customers leaving reviews sits at around one percent according to the sector inquiry (Bundeskartellamt); with active asking it is clearly higher, but well below what you picture on the first attempt. The sector-dependent figures — from the single digits on energy comparison sites to 14.5 percent (Bundeskartellamt) on hotel comparison sites — show the range. A business with personal contact and a short path tends to land somewhere in between (project experience).

A worked example without magic

A plumbing firm completes 40 jobs a month. On 30 of them someone is on site who actually voices the request. If 10 percent of those come back, that is three reviews a month — 36 a year. It is unspectacular, and that is the point: a profile with 36 genuine, dated reviews accumulated over a year reads as more credible than one where 25 five-star entries appear within a single week. Evenness over time is a quality signal, not a drawback.

Expect, too, that a portion of the reviews submitted will not become visible. Across all portals surveyed, an average of 7 percent (Bundeskartellamt) of submitted reviews are withheld from publication because of filtering measures. That is not directed at your business; it is the portals' attempt to filter out conspicuous patterns. It does occasionally catch genuine customers, for instance when several reviews arrive in quick succession from the same network. One more reason not to have every customer review you from the same waiting room on the same afternoon.

The limits set by competition law

The rules for reviews are drawn at European level. Directive (EU) 2019/2161 adapted consumer law to digital sales channels and addressed reviews explicitly; Member States have applied the new provisions since 28 May 2022 (Directive (EU) 2019/2161). In Germany the prohibitions sit in the annex to Section 3(3) of the Act against Unfair Competition — in numbers 23b and 23c. That list contains commercial practices which are unlawful in all circumstances; no case-by-case balancing takes place.

Submitting or commissioning fake consumer reviews or endorsements, as well as misrepresenting consumer reviews or endorsements on social media.

Annex to Section 3(3) no. 23c UWG (Gesetze im Internet, German Federal Ministry of Justice)

Number 23b covers the other side: it is unlawful to claim that reviews come from consumers who have actually bought or used the service without having taken reasonable and proportionate steps to verify this (UWG). For the collection process that means: if you write that all reviews come from real customers, you need a traceable procedure behind it — matching against a job number, for example. The table below sorts the plans that come up most often in practice.

PlanAssessmentReasoning
Asking for a review after completionPermittedA request without anything in return is a nudge. The Bundeskartellamt still classes reviews prompted by a reminder as classic reviews (Bundeskartellamt).
One friendly reminderPermitted, in moderationPortals prompt repeatedly in some cases (Bundeskartellamt). For a small business a request plus one reminder is enough; following up more often exerts pressure on the content.
Voucher or discount for a reviewDelicate to unlawfulIncentives produce more reviews and better ones. Without a clearly visible disclosure the Bundeskartellamt sees this as misleading under Section 5(1) UWG (Bundeskartellamt).
Voucher only for five starsUnlawfulThis influences the content. In such cases the Bundeskartellamt speaks of a manipulated review (Bundeskartellamt).
Writing reviews yourself or having them writtenUnlawfulThe annex to Section 3(3) UWG prohibits fake reviews and their commissioning without exception (UWG).
Publishing only the favourable responsesUnlawfulDirective (EU) 2019/2161 prohibits the targeted filtering out of negative voices; the implementation sits in the annex to the UWG (Directive (EU) 2019/2161).

How widespread incentives are is clear from the sector inquiry: about 20 percent (Bundeskartellamt) of the portals surveyed use vouchers as an incentive, and in the product review segment prize draws are used at least occasionally by 40 percent (Bundeskartellamt) of portals. Legally such incentives are not banned outright — the Bundeskartellamt considers them permissible where they are disclosed, while pointing to a ruling of the Higher Regional Court of Frankfurt am Main which found a prize draw for reviews without a corresponding notice to be misleading (Bundeskartellamt). For a small business the arithmetic is simple: the effort of a clean disclosure outweighs the benefit of the incentive in nearly every case.

The safe route: nothing in return

A free drink for a review, five euros off the next visit, entry into a prize draw — each raises the number of reviews and shifts them upwards, because people reciprocate a gesture. The Bundeskartellamt describes exactly this reciprocity as the reason incentivised reviews come out better on average (Bundeskartellamt). Skip the incentive and you have nothing to disclose, nothing to weigh up and nothing to document — plus the more honest result.

The narrow ridge: asymmetric nudges

One practice looks harmless and still counts among the patterns assessed critically. The Bundeskartellamt quotes a typical prompt: „Are you happy? Write it online. Are you unhappy? Write to us." (Bundeskartellamt). It sounds customer-friendly, but it steers praise outwards and criticism inwards. The result is a public picture that looks better than actual satisfaction. The Bundeskartellamt calls such constructions asymmetrically selected reviews and classes them as a breach of fair trading law (Bundeskartellamt).

The authority also describes the refined variant: an online shop that asks every customer by email for a star rating but forwards only those who rate positively to a detailed review on a portal (Bundeskartellamt). On this reading a nudge already becomes asymmetric when leaving a poor review is more cumbersome than leaving a good one — for instance because one click covers „satisfied" while „dissatisfied" demands an explanation (Bundeskartellamt).

  • Two different paths depending on mood: a public link for praise, an internal form for criticism
  • A preliminary satisfaction question that decides where the customer is forwarded
  • Different effort levels: one click for the good review, a form with mandatory fields for the poor one
  • The request is voiced only to customers whose job ran smoothly
  • A card with a QR code that is placed on the table only for visibly satisfied guests

The permissible counterpart is unspectacular: the same path for everyone, the same wording, the same number of reminders. An additional internal channel for criticism is allowed and even sensible — it simply must not replace the public one. Frame it as an addition: „You can write that online or call us directly, whichever you prefer." What such an internal feedback path looks like technically, without becoming a dead end, is described in the article on contact forms and enquiries.

Reviews from your own team and circle

When the first weeks drag, a shortcut suggests itself: a sister-in-law writes two lines, the apprentice sets up a profile, the tax adviser returns the favour with five stars. Legally this is the clearest case in the whole field. Reviews not based on actual use or experience count as non-authentic (Bundeskartellamt) and fall under the prohibition in number 23c of the annex to Section 3(3) UWG (UWG). Whether money changed hands is beside the point.

  • Employees reviewing the business without having been a customer: non-authentic, and therefore unlawful
  • Family members and friends with no connection to a job: the same case, regardless of the wording
  • Reciprocal reviews with friendly businesses: likewise without genuine customer experience
  • Bought texts via intermediaries: for its inquiry alone the Bundeskartellamt wrote to 30 commercial review brokers (Bundeskartellamt) — the market exists, and so does the prohibition
  • A review drafted by the business that the customer merely confirms: that crosses the line into misrepresentation

When employees really were customers

The special case does exist: the office manager has her heating serviced privately, the chef orders catering from his own firm for a family celebration. Such a review rests on genuine experience. It is still only clean with the connection disclosed — a note that the person works at the business and used the service privately. Without that note readers form a false impression of independence, and misrepresentation is exactly what the prohibition targets.

Replying to criticism as visible proof of trust

The reply from the business is the most underrated part of the subject. According to the studies evaluated by the Bundeskartellamt, personal replies from providers to reviews play a major role in building consumer trust (Bundeskartellamt). That makes sense: an unanswered complaint stands alone. A factual reply next to it shows that someone is listening, that there is a contact person and that problems get worked on. In the end the reader is judging the handling, not the complaint.

Prompt and factual

Reply within a few working days, in full sentences and without irony. The tone of the reply is read by future customers, not only by the author of the criticism. Defending loses ground; explaining gains it.

Address the point

Name the specific criticism without repeating and amplifying it. „The appointment slipped through on our side" carries more weight than any general formula. A demonstrable clarification is fine; arguing about the customer is not.

Offer a route

Close with a concrete next step: a direct line, a name, an offer to sort it out. That moves the conversation where it belongs without cutting off the public reply.

On data protection the line is simple: reply without details from the customer file. Naming the reason for treatment, the invoice amount or the address in public in order to justify yourself processes personal data in a context where it does not belong. Even where the author mentioned those details first, restraint remains the better route. Which mandatory information and notices a website needs alongside this is set out in the article on imprint and privacy policy.

  • Every review with text gets a reply, positive as well as negative — equal treatment is the principle here too
  • The reply names no job details that are not already public in the review text
  • In cases of mistaken identity, the reply notes factually that no job can be matched, instead of imputing intent to the author
  • Legally problematic content is handled through the portal's reporting route, not through a public dispute
  • Recurring criticism goes into the internal process review, not only into the reply
  • One named person writes the replies, so the tone stays consistent across all reviews

Your own review page as the hub

All the building blocks so far converge in one place: a dedicated page on your website that the QR code and the link point to. It has three advantages over a direct link to a portal. First, the address stays the same even when portals, profiles or priorities change. Second, you can explain how it works instead of leaving customers in front of a sign-in screen. Third, it is the natural home for the mandatory notice on whether and how you verify authenticity — information that counts as material under Section 5b(3) UWG as soon as you advertise with reviews (UWG).

  • A heading that names the purpose, and two sentences on why feedback helps
  • One clearly labelled link per portal on which your business is actually listed — with a note that an account may be required there
  • A short three-step guide, so that less practised users get through
  • An equivalent path for criticism that is not meant to be public: phone number and form
  • The notice on verifying authenticity, in readable size and on the same page
  • One sentence stating that there are no discounts, vouchers or other benefits in return for a review

This is exactly the kind of page you can create in XICflow within minutes: you describe what belongs on the page, pick one block for the instructions and one for the portal links, and the page is delivered statically — with no third-party scripts loaded, a short address and a dedicated place for the verification notice. What such a page looks like in a finished result is shown by the demo websites; which blocks are available for it is described in the feature overview. Which pages a business website needs beyond that is covered in the article on the pages a business website really needs.

Two additions complete the picture. Anyone who wants to be found locally needs, alongside their own page, a well-kept profile in the map services — including how to handle the reviews arriving there, which the article on the Google Business Profile describes. And once the first voices have come in, the question of presentation arises: which notice has to sit where, and which quotes actually convince, is set out in the article on reviews on your website.

What counts in the end

The road to genuine reviews is unspectacular: ask in person at the right moment, shorten the path to two steps, hang the task off an existing routine, offer nothing in return, and reply to criticism as though every future customer were reading along — which they are. Anything that looks faster is either unlawful or fails the first closer look. Twelve honest reviews across a year carry more weight than fifty that appeared in a single week.

Sources and studies

This article is based on data from: the sector inquiry into user reviews by the German Federal Cartel Office (Bundeskartellamt), final report of October 2020, with responses from 62 portals and 67 evaluated questionnaires; the German Act against Unfair Competition (UWG), in particular Section 5b(3), Section 7(3) and the annex to Section 3(3) in numbers 23b and 23c, published via Gesetze im Internet by the German Federal Ministry of Justice; Directive (EU) 2019/2161 on the better enforcement and modernisation of Union consumer protection rules; the consumer information and market check on online reviews by the Federation of German Consumer Organisations (vzbv); a representative survey by Bitkom on information behaviour before purchase; and our own project experience.