Review removal law by country

The short version

Two separate routes exist, and it matters which one your country gives you.

The policy route works everywhere, without exception. Google publishes one global content policy, and any business anywhere can report a review that breaks it: fake reviews, reviews from people who were never customers, competitor reviews, harassment, off-topic content. This is the route that resolves most cases, and it is the same in Sarajevo as in Munich.

The legal route means using national law to require Google to remove a review. This one varies enormously, and in some countries it does not exist at all. The table below is about the legal route only.

Country	Legal route against Google	Realistic outcome
Germany	German defamation law plus DSA notice; "not a customer" claim	Strongest in the world
Italy	Art. 700 urgent injunction; a court has ordered removal and rating restoration	Strong on demonstrated results
Spain	Organic Law 1/1982; removal is an express statutory remedy	Moderate to strong
France	LCEN and DSA notice, then urgent proceedings	Moderate, with a three month deadline
Netherlands	Art. 6:196c(4) Civil Code duty after formal notice	Moderate, reviewed one by one
Austria	DSA notice; Austrian civil law on commercial reputation	Moderate
United Kingdom	Defamation Act 2013 section 5 notice	Possible, with a high evidence bar
Australia	Defamation law for small businesses; consumer law for larger ones	Possible, slow and costly
United States	None against Google (Section 230)	Policy route only
United Arab Emirates	None against Google	Policy route only
Bosnia and Herzegovina	None against Google; no DSA applies	Policy route only

Three countries in that table say "policy route only". That is not a reason to give up: the policy route is where most successful removals happen anyway, including in Germany. It simply means we tell you honestly that there is no second lever if Google says no.

Germany and Austria

Germany is the most favourable jurisdiction in the world for businesses challenging reviews, and Google says so itself. Google's help page on defamation removal notices in Germany states that German courts have set a low threshold for businesses to challenge reviews as defamatory, that a business can claim the reviewer was not a customer, and that unless there is evidence to the contrary, courts generally order platforms to remove such reviews.

The scale confirms it. Analysis of the EU's Digital Services Act transparency database shows that almost all Google Maps reviews removed for defamation across the entire EU involve businesses based in Germany. The mechanism is a notice under the DSA's notice and action rules, combined with German law on commercial reputation. The old NetzDG was repealed in May 2024 and replaced by the DSA framework, but the substantive German law that makes the route work is unchanged.

There is a cost to know about. Google now displays a public counter on German Business Profiles showing how many reviews were removed after defamation complaints, in ranges from "one review" up to "over 250". We tell every German client this before we start, because a visible counter is a reputational trade-off that only you can weigh.

Austria shares the DSA notice mechanism and protects commercial reputation under its civil code, but it does not have the same body of case law on platform removal. We treat Austrian cases as moderate rather than strong and say so in the assessment.

Italy

Italy has produced the clearest court win against Google that we are aware of. In November 2022 the Court of Genoa heard the case of a restaurant that had received around seventy fake negative reviews in a single month. Some were obviously false: one complained about the pizza, which was not on the menu, and another called it the worst place in Rome, while the restaurant is in Genoa. The rating fell from 4.7 to 3.4 and Google had refused to remove the reviews, saying they met its guidelines. The court ordered Google to remove them and to restore the previous rating, and awarded costs against Google.

The structural advantage is Article 700 of the Code of Civil Procedure, which allows urgent injunctive relief. Because websites are not legally "the press" in Italy, they do not enjoy the protection against preventive injunctions that registered newspapers do. Businesses can also rely on Article 2043 of the Civil Code for damages, or Article 2598 on unfair competition where a competitor is behind the reviews.

Criminal defamation under Article 595 of the Criminal Code is available, but the complaint must be filed within three months of learning about the review. Italy sits below Germany because there is no burden-shifting shortcut: Genoa succeeded on manifest falsity, which is an unusually clean fact pattern.

Spain

Spain has the clearest position of any country on a question that blocks businesses elsewhere: whether a company, rather than a person, can defend its reputation at all. The Constitutional Court settled this in 1995, holding that the right to honour cannot exclude legal persons from its scope, and later case law treats professional prestige as part of a company's honour.

The instrument is Organic Law 1/1982. Article 7.7 covers statements that injure dignity and diminish reputation, and Article 9.2 makes removal an express statutory remedy, not merely a basis for damages. Article 9.3 presumes harm once unlawful interference is established, so you do not have to prove financial loss. Where a competitor is behind the review, the Unfair Competition Act offers a parallel route.

What Spain lacks is Germany's procedural shortcut. There is no equivalent of the "the reviewer was not a customer" argument that shifts the burden, so a Spanish case is decided on its merits and needs real evidence.

France

France gives businesses a real route, and one hard deadline that catches most people out. Defamation is governed by the Press Law of 29 July 1881, and under Article 65 the limitation period is three months from publication, not from the day you discovered the review. Most businesses find a damaging review long after it was posted, and by then the defamation claim is time barred.

The alternative is dénigrement, commercial disparagement under Article 1240 of the Civil Code, which has a five year limitation period and does not require proving that the statement was false, only that it was disparaging and aimed at diverting custom. The two grounds cannot be combined, so choosing correctly at the start matters.

Against Google itself, a compliant notification under the LCEN creates presumed knowledge, and urgent proceedings can follow. French courts have been clear about the limit: in decisions of the Paris courts, merely negative or unpleasant comments were held not to justify removal in urgent proceedings without established defamation, insult or disparagement.

One point of French law shapes how we work everywhere: notifying content as unlawful while knowing the information is inaccurate is itself an offence under the LCEN, punishable by imprisonment and a fine. That is aimed at whoever files the notice. It is one reason we refuse cases where the review is simply an honest complaint.

Netherlands and the wider EU

Every EU member state has the DSA's notice and action mechanism: a sufficiently precise, substantiated notice gives the platform actual knowledge of illegal content and puts its liability shield at risk if it does not act. Businesses in the European Economic Area can also report reviews to Google through a direct channel that is not available elsewhere.

In the Netherlands the specific hook is Article 6:196c(4) of the Civil Code: once a hosting provider is aware that content is unlawful it must remove it, and after a formal lawyer's letter Google can hardly claim doubt. Cases proceed through summary proceedings, and Dutch courts have ordered Google to hand over the data identifying reviewers where the reviews were evidently unlawful.

Dutch judges assess each review separately and are genuinely sceptical. In one reported case involving four reviews, only one was ordered removed. The line they draw is useful to understand: harsh criticism, disappointment and subjective experience must be tolerated, while a concrete factual accusation such as fraud or theft can be unlawful. Other EU countries outside Germany, Italy, Spain and France follow the same general pattern and we assess them case by case.

United Kingdom

The Defamation Act 2013 gives businesses a real but narrow route. Two gates matter.

First, section 1: a statement is not defamatory unless it has caused or is likely to cause serious harm, and for a company trading for profit that means serious financial loss. A single bad review rarely clears this on its own; a pattern that can be tied to lost bookings or contracts may.

Second, section 5 and the Defamation (Operators of Websites) Regulations 2013. A website operator has a defence if it did not post the statement, but loses it if the complainant could not identify the poster, sent a proper notice of complaint, and the operator failed to follow the regulations. Under those regulations the operator must, within 48 hours, either remove the content or forward the notice to the poster; if the poster does not respond within five days or cannot be contacted, the operator must remove the content to keep its defence. If the poster contests, the operator does not have to remove it, and the complainant must pursue the poster directly.

So the UK route works best against anonymous reviewers who will not engage, and least well against a real customer who stands by what they wrote. We prepare the notice; a solicitor is involved where the case goes further.

Australia

Australian defamation law is available to businesses only if they are small: under the uniform defamation legislation, a company with ten or more employees cannot sue for defamation at all. Larger businesses must rely on other causes such as injurious falsehood or misleading conduct under the Australian Consumer Law, which have different and often harder elements.

Australian courts have been more willing than US courts to treat Google as a publisher in some circumstances, so a route exists. It is slow, expensive and fact-specific. For Australian clients we run the policy route first and assess the legal route honestly, usually with a local lawyer's view before any commitment.

United States

Section 230 of the Communications Decency Act shields Google from liability for content its users post. The courts have applied this since the 1997 Zeran decision even where the platform was told the content was defamatory and declined to remove it. There is no notice and takedown mechanism for defamation, and no legal lever against Google itself.

What remains is Google's own policy reporting route, which is free and available to every profile owner, and the option of suing the reviewer, obtaining a court finding that the statement is defamatory, and then asking Google to honour that order. In practice the second path is blocked by anonymous reviewers and by anti-SLAPP laws that penalise suits over ordinary criticism.

Two federal rules also constrain what anyone may do. The FTC's rule on consumer reviews makes it unlawful for anyone to use unfounded legal threats or intimidation to get a review removed, with civil penalties per violation, and the FTC holds businesses responsible for what vendors do on their behalf. And Google's policy prohibits offering reviewers anything of value to remove a review. A US review removal service is therefore, honestly described, disciplined execution of a free process. That has value in the right cases. It is not a legal mechanism, and we will not describe it as one.

United Arab Emirates

For a business in Dubai or elsewhere in the UAE, the policy route is the route. We report reviews that break Google's content rules exactly as we would for a client in Munich or Manchester, and those reports succeed on the same grounds: fake reviews, reviewers who were never customers, competitor reviews, harassment, off-topic content.

What the UAE does not give you is a legal lever over Google. The country's mechanism for online content is network level blocking through the telecommunications regulator, which applies to access from inside the UAE rather than ordering a platform to delete something. Blocking a Google Maps listing would hide your own business from local users, which is the opposite of what you want. A UAE court order also has no automatic force over Google abroad.

UAE law does treat online defamation as a criminal matter, with serious consequences for the person who posted the review, including fines, imprisonment and deportation for foreign nationals. We do not offer that route and we do not advise clients to pursue it. Removing a review should not cost someone their liberty or their residence, and a business that is seen to have done so rarely comes out ahead.

Bosnia and Herzegovina

Bosnia is served through the policy route, which works there as it does anywhere: a review that breaks Google's content rules can be reported and removed regardless of which country the business is in.

There is, however, no legal route to fall back on. Bosnia is not an EU member, so the DSA does not apply and there is no national equivalent, no notice and action procedure and no hosting liability regime to put pressure on a platform. Defamation is handled under entity level civil laws in the Federation and Republika Srpska. Those laws do protect companies as well as individuals, which is more than some countries offer, but they are built around compensation from the author rather than removal by the platform, and an order stopping further publication requires showing near certainty of harm.

So for a Bosnian business the honest position is this: we will report what qualifies, prepare the evidence properly and use the single appeal well, and if Google declines there is no second door to knock on. We would rather say that at the start than after you have paid someone.

What this means for you

Before you commit money to any review removal service, including ours, ask two questions: which route will actually be used for my review, and what happens if it fails. In our case the answers are on this page and on the pricing page: the policy route everywhere, the legal route where it genuinely exists, and no charge for reviews that are not removed.

Nothing here is legal advice. It is a plain-language summary of public sources, written so that you can have a sensible conversation with a lawyer if one is needed.