Reviews, testimonials and before and after images

The UK rules that apply before a review is published

A review on a beauty business website, in an advert, in a social post controlled by the business, or in a campaign supplied to a creator can become marketing communication. That matters because the business is not merely passing on a client view. It is selecting, presenting and often amplifying that view to influence a purchase decision.

The CAP Code says that marketing communications must not materially mislead, and that objective claims must be supported by documentary evidence. Its rules on testimonials and endorsements require that they are genuine, relate to the experience of the person giving them, and are not used in a way that creates a misleading impression. The Code also requires permission before a testimonial or endorsement is featured in marketing communication.

The Advertising Standards Authority applies the CAP Code when considering complaints about non broadcast advertising. Published ASA rulings on testimonials and on before and after imagery repeatedly examine whether the advertiser can substantiate the claimed result, whether the material is representative of what a consumer can expect, and whether presentation alters the apparent outcome. A ruling is tied to its own evidence and advertisement, but it shows how those Code requirements are applied in practice.

The Digital Markets, Competition and Consumers Act 2024 includes banned practices concerning fake consumer reviews. It addresses submitting or commissioning a fake review, and publishing consumer reviews without taking reasonable and proportionate steps to prevent their publication. The Competition and Markets Authority guidance on online reviews and endorsements explains the consumer protection concerns around concealed incentives, selective presentation and misleading review processes. These are not optional issues for a business that actively collects or republishes feedback.

When a testimonial becomes an advertising claim

A testimonial may be personal opinion, but it can still communicate an objective claim when it says or clearly implies that a treatment delivered a particular effect. A statement such as “I felt relaxed” is different from a statement that a service removed a condition, permanently changed a physical feature, or produced a defined result for a stated period. Context, accompanying captions and the surrounding sales message all matter.

The CAP Code distinguishes between claims that can be assessed objectively and subjective expressions of opinion. Where a testimonial makes an objective claim, the advertiser needs documentary substantiation for that claim. The fact that a real client said it does not itself establish that the outcome can be expected, or that the wording is suitable for marketing. The ASA can assess the overall impression given to the audience rather than treating quotation marks as a complete answer.

The CAP Code also contains rules for health, beauty and slimming claims. Those rules are particularly relevant where a beauty business moves from describing appearance or experience into a claim about health, disease, diagnosis, treatment or physiological effect. This page does not determine whether a particular statement is lawful. A business facing that question should obtain appropriate legal advice and should not assume that client wording avoids the issue.

The Competition and Markets Authority guidance on online reviews and endorsements also addresses misleading presentation. Removing all less favourable reviews, displaying a handpicked set as though it were the full picture, or using a process that rewards only positive sentiment can distort consumer understanding. A smaller collection of verifiable, fairly presented reviews is generally easier to explain and audit than a large collection with no reliable record.

Decision rule to save before publishing

If a reasonable prospective client could read the testimonial as evidence that they will receive a defined result, treat it as an advertising claim: verify the reviewer, retain the original wording, obtain permission, assess the claim against the CAP Code, and disclose any relevant incentive.

Before and after images: what the image itself claims

A before and after image is often more persuasive than a written claim because it invites a direct visual comparison. It can imply change, speed, permanence, typicality or treatment efficacy even where the caption is brief. The CAP Code requirement that marketing communications must not mislead applies to the whole presentation, including cropping, lighting, angle, distance, facial expression, make up, styling and image processing.

ASA rulings on before and after imagery show why a business should be able to explain the conditions under which the images were made. Material differences between the two pictures may create a misleading impression if they exaggerate an apparent effect. The relevant question is not whether any editing occurred in a technical sense. It is whether the final presentation gives consumers a materially inaccurate impression of the advertised service or outcome.

For a service business, the image record should identify the client, date, treatment or service represented, relevant interval between images, photographer or staff member, and any consent limits. That record is operational evidence, not material that needs to be published in full. It enables the business to answer a challenge about what the images show.

Captions deserve the same care as the image. A caption should not claim an outcome that the image cannot demonstrate. It should not turn one person’s result into a promise for others. If a material condition affects interpretation, such as an interval after a service, the business should consider whether omitting it would change the audience’s understanding. The CAP Code and ASA rulings are the relevant advertising sources for this assessment.

Digital Gloss editorial standard for reviews and images

This publication uses the following standard when assessing whether a review, testimonial or before and after image appears compliant enough to discuss without qualification. It is an editorial test, not a regulatory finding and not legal advice. A failure in any one part does not decide a legal case. It identifies the point that requires correction, evidence or professional review.

1. Traceability. The business can identify the original review or image record and the person or client involved. Anonymous publication may be appropriate, but internal traceability still matters. This reflects the fake review concerns addressed by the Digital Markets, Competition and Consumers Act 2024.
2. Permission. There is recorded permission for the intended marketing use. This follows the CAP Code requirement on permission for testimonials and endorsements.
3. Accuracy. The wording and image do not make an objective claim that the business cannot substantiate. This reflects the CAP Code rules on misleading advertising and substantiation.
4. Context. The selection, caption and visual presentation do not conceal a material factor that changes the likely consumer understanding. This is assessed against the CAP Code and the approach visible in ASA rulings.
5. Incentive clarity. Any payment, discount, gift, entry or other benefit connected with the review is recorded and assessed for clear disclosure. This reflects Competition and Markets Authority guidance on online reviews and endorsements.
6. Fair process. The method for requesting, moderating and publishing reviews includes proportionate safeguards against false material and does not create a misleadingly selective picture. This reflects the Digital Markets, Competition and Consumers Act 2024 and CMA guidance.

Checklist before publishing a testimonial or image

Use this checklist for each item, rather than relying on a general permission form or a staff memory of the appointment. It is designed to create a usable publishing record. The CAP Code, ASA rulings, the Digital Markets, Competition and Consumers Act 2024 and CMA guidance remain the source material where a difficult point needs interpretation.

1. Find the original review, message or image file and record where it came from.
2. Confirm that the person is a real client or customer and that the experience described is theirs.
3. Keep the original language. If editing is needed for length or clarity, do not change its meaning or strengthen its claim.
4. Obtain permission for the specific promotional use, including the intended channel where practical.
5. Record any incentive, payment, discount, gift, free service or competition entry connected to the review.
6. Check whether the testimonial makes an objective claim. If it does, locate supporting evidence before publication.
7. For images, compare lighting, angle, distance, styling, expression, image quality and editing across both photographs.
8. Record the relevant dates and interval represented by a before and after pair.
9. Read the caption with the image and remove language that promises a result or implies that the outcome is typical without support.
10. Check that moderation has not removed or suppressed material in a way that produces a misleading overall picture.
11. Store the permission, source material and publication record together so the item can be reviewed later.

A practical internal rule is to pause publication where staff cannot answer who supplied the item, what changed between image sessions, whether an incentive was involved, or what evidence supports an outcome claim. A pause is cheaper than trying to reconstruct the record after a complaint.

Records, incentives and review collection systems

A review collection process can be sound without being elaborate. The Digital Markets, Competition and Consumers Act 2024 uses the idea of reasonable and proportionate steps in relation to fake consumer reviews. What is proportionate will depend on the business, the volume of reviews, the collection method and the risk of manipulation. The important practical point is that passive publication is not a complete answer where a business operates or controls the review process.

Keep a simple record of review requests, responses, incentives, moderation decisions and removal reasons. This allows a business to distinguish between removal for an identifiable policy reason, such as abusive content or an unverifiable submission, and removal because the review is unfavourable. The CMA guidance on online reviews and endorsements is particularly relevant to systems that invite reviews after a transaction and then present selected material in marketing.

An incentive is not made neutral merely by calling it a thank you. A benefit may affect how consumers interpret the independence of the review, especially if it is offered only for favourable feedback or if the benefit is not made clear. The CMA guidance addresses endorsements and review practices that can mislead through hidden commercial influence. The CAP Code also applies where the review is used in advertising.

Businesses should separate two decisions. The first is whether feedback is suitable to publish on a review channel. The second is whether it is strong enough, evidenced enough and contextualised enough to use in an advertisement. The second decision is normally stricter because the business has actively selected the material to sell a service or product.

Professional help and disclosure

Some businesses will need outside help to build a robust process. Appropriate categories include review platform software that records collection and moderation activity, legal review for difficult consumer protection or advertising questions, photography standards for repeatable image capture, consent and records management support, and staff training on claims approval. The need depends on the services offered, the scale of advertising and the risk created by the claims being made.

Professional input does not transfer the business’s responsibility for the marketing it publishes. A supplier can support record keeping or image consistency, but the advertiser should still understand what was approved, why it was approved and what evidence is held. The CAP Code and ASA process concern the advertising communication, while the Digital Markets, Competition and Consumers Act 2024 and CMA guidance address consumer review practices more broadly.

Disclosure

This page carries no commercial relationship at present. If it later contains a paid or affiliate link, that link will be labelled and will carry rel sponsored. Editorial assessment is not sold.

Limits of this reference

This reference concerns UK advertising and consumer review issues for beauty businesses. It does not cover every privacy, data protection, intellectual property, employment, platform, professional standards or clinical issue that may arise when a business records and publishes client material. It does not replace the CAP Code, the ASA process, the Digital Markets, Competition and Consumers Act 2024, Competition and Markets Authority guidance, or advice from a solicitor qualified to advise on the specific facts.

It is not a guide to creating medical claims, nor does it assess whether a treatment is appropriate, safe or effective. Businesses operating in regulated clinical settings, using protected titles, making disease related claims, or handling especially sensitive client information may face additional duties outside the scope of this page. In those circumstances, a review or image approval process should be considered alongside the relevant sector rules and legal advice.