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The necessary ‘reasonable and proportionate’ steps are to be assessed taking into account, inter alia, the trader’s business model – an online marketplace that presents the reviews of its own customers may have to apply different measures than a specialised review service that invites reviews from the wider public without having a contractual relation. Also the scale of the trader’s activity and the level of risk should be taken into account for establishing what is ‘reasonable and proportionate’ for that given trader. For example, large platforms with a high risk of fraudulent activity and larger resources would be expected to deploy more significant means to counter the fraud with consumer reviews than smaller traders.

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Source: EUR-Lex (Cellar) · retrieved 2026-09-25 · Text as adopted (Official Journal); later amendments are not incorporated in this text.