Scenario: a newly opened fashion store on an e-commerce marketplace hires an “order-boosting” service — hundreds of fake orders daily, each with 5-star reviews and praise from accounts that never received any goods. Within a month the shop tops search rankings and real sales surge. The owner believes this is just a “marketing tactic”. Does the law agree?
What is seeding in legal terms?
Seeding in e-commerce covers: creating fake orders (no real delivery), writing fabricated product reviews and comments, and manipulating sales figures, likes and ratings. In substance, it is the provision of false information about products, goods or services to deceive consumers — whether performed by the seller itself, an agency, or hired accounts.
The legal framework against seeding
Law No. 122/2025/QH15 on E-Commerce (effective 1 July 2026) requires sellers to publish truthful product information and prohibits fraud in e-commerce. The Advertising Law 16/2012/QH13 (amended by Law 75/2025/QH15, effective 1 January 2026) prohibits misleading advertising about product functions and quality — fake reviews are a disguised form of misleading advertising. At the sanctions level, Decree 98/2020/ND-CP (amended by Decree 24/2025/ND-CP, adding Article 53a) punishes violations in online transactions with consumers, including “using measures to display consumer feedback and reviews untruthfully” — fines of VND 50–70 million for digital platform operators. Sellers who directly seed face fines for providing false, deceptive information to consumers under trade and consumer-protection sanction rules.
Platform responsibility for fake reviews
Platforms may not tolerate fake reviews. Under Article 53a of Decree 98/2020/ND-CP (added by Decree 24/2025), a digital platform operator faces a VND 50–70 million fine for untruthfully displaying consumer feedback — except where the feedback itself violates the law or social ethics. The 2025 E-Commerce Law also obliges platforms to build mechanisms controlling the authenticity of transactions and reviews. In practice, major marketplaces deploy algorithms detecting fake orders and reviews and suspend violating storefronts — but those are internal measures, not substitutes for state sanctions.
How are deceived consumers protected?
The Consumer Protection Law 19/2023/QH15 (effective 1 July 2024) gives consumers the right to truthful product information and the right to complain and claim compensation when deceived. Buyers who find the actual product far below its review-inflated description may demand returns and refunds under platform policies and the law, and may report the fraud to market surveillance authorities. Competitors harmed by a rival’s seeding may sue for damages under unfair-competition rules (Competition Law 23/2018/QH14).
Frequently asked questions
Is hiring a KOL to review a product considered seeding?
No — if transparent. Paid influencer reviews are lawful advertising, but amended Advertising Law 75/2025/QH15 requires sponsored content to be labelled “advertisement”. A paid review pretending to be an objective customer experience, hiding the sponsorship, is seeding and punishable.
What about asking relatives to place real orders and leave honest reviews?
Genuine orders (real delivery, real payment) with truthful reviews are not prohibited. The line is honesty: fabricated orders and invented reviews violate the law. Platforms may still treat coordinated ranking manipulation as a breach of their internal rules, however.
Can order-boosting service providers be punished?
Yes. Providers of fake-order and fake-review services are accomplices in deceiving consumers and face administrative fines; where illicit gains are large-scale, criminal liability for deceiving customers (Article 198 of the 2015 Penal Code) may be considered.
This article has been quality-reviewed by the FLAW AI Legal Council.