Here, we add to the debate as to whether false recognition of emotional stimuli is more memory-based or more bias-based. Emotional false memory findings using the DRM paradigm have been marked by higher false alarms to negatively arousing compared to neutral critical lure items. Explanation for these findings has mainly focused on false memory-based accounts. However, here we address the question of whether a response bias for emotional stimuli can, at least in part, explain this phenomenon. In Experiment 1, we used a criterion warning, previously shown to increase more conservative responding and reduce false recognition. Experiment 2, we employed a two-alternative-forced choice test, which minimises the role of criterion setting. In both experiments, we compared false alarms to negative and neutral critical lures. We observed a significant decrease in false recognition rates for both negative and neutral critical lures under the conditions of forced choice restriction and criterion warning. However, despite these conditions, negative items, compared to their neutral counterparts, still consistently provoked a higher degree of false recognition. The discussion that follows presents an exploration of both memory-based accounts and criterion-setting explanations for the enhanced emotional false memory finding.