Black Friday and Christmas sale pricing rules for UK online shops (2026 checklist)

A good sale is an honest one: the discount is real, the price you show is the price people pay, any deadline is true, and the reviews are genuine. That is also most of what the law asks for. You don't need a countdown timer that resets, or a “was” price nobody ever paid. This checklist is for UK businesses selling goods to consumers online. It is general information, not legal advice.

1. What changed: the DMCC Act and CMA fines

The unfair commercial practices rules in Chapter 1 of Part 4 of the Digital Markets, Competition and Consumers Act 2024 (DMCC Act) came into force on 6 April 2025 (SI 2025/272, regulation 2). They replace the Consumer Protection from Unfair Trading Regulations 2008 and, the CMA says, keep much of the same scope, with new or more detailed rules on fake reviews and drip pricing (CMA207).

The big change is enforcement. The CMA can now decide for itself that consumer law has been broken, without going to court first, and its guidance says it can impose penalties of up to £300,000 or, if higher, 10% of a business's worldwide turnover (CMA200, paragraph 7.11). Most of the 32 practices banned outright in Schedule 20 are also criminal offences (CMA207). Trading Standards still enforce through the courts too.

2. “Was £80, now £49”: make the reference price real

A reference price is the higher price you compare against: your own earlier price (“was/now”), a future price (“introductory offer”), a recommended retail price (RRP) or a competitor's price. The CMA's 2023 open letter on online urgency and price claims says the higher price must be a genuine and realistic selling price, and that you should be able to show it (CMA urgency and price reduction claims). The Chartered Trading Standards Institute's pricing guidance, updated for the DMCC Act, lists what makes a “was” price more or less likely to be genuine (Guidance for Traders on Pricing Practices, section 17):

How long it was charged. Running the sale for longer than the product was on sale at the higher price is less likely to comply.
How recently. A price charged many months ago is unlikely to show the item's current value.
Whether it was the last price. If the item has already been sold at a lower price in between, “was £500” is less likely to be genuine.
Whether people actually bought at it. Evidence of significant sales at the higher price, or that it was a realistic selling price, helps. Repeatedly using a price you know hardly sold does not.
Seasonal tricks. Charging a high price out of season and then “cutting” it for the season is less likely to comply.
RRPs. Label an RRP clearly as an RRP, make sure it is a genuine selling price, and don't set or influence it yourself. Ask your supplier for evidence.
After-sale prices. If you say the price goes up after Black Friday, it needs to actually go up.

The CMA also tells businesses to keep records that show price claims reflect real selling conditions, and to make sure offer prices don't carry on beyond the promotion's end date (CMA open letter). A simple dated price history for each sale item, such as screenshots or a platform export, is the easiest way to do this.

The rules may get stricter. On 9 August 2026 the government announced a consultation, planned for this autumn, on whether fake “was” prices, invented discounts and misleading RRPs should be added to the DMCC Act's list of practices that are always banned (GOV.UK). Check that page for updates before you plan next year's sales.

3. No drip pricing: put mandatory fees in the headline price

When you show a product and its price, the DMCC Act treats that as an “invitation to purchase”. The total price is material information, and it includes any fees, taxes or charges the customer will necessarily pay if they buy (DMCC Act, section 230(2)(b) and (4)). The CMA says showing a headline price and then adding mandatory charges as the customer goes through checkout, known as drip pricing, is prohibited (CMA207). Its price transparency guidance explains what that means for an online shop (CMA209 summary):

Mandatory fees go in the price. A booking, service or “processing” fee that every customer must pay belongs in the price, even in early adverts.
Delivery you can't avoid. If delivery is mandatory and you can reasonably work it out, include it in the total price. If it varies, for example by location, give enough information for people to work out the total, as prominently as the headline price.
Optional delivery, such as next-day, can be shown separately. If customers must pick a delivery option, show the cheapest one until they choose another.
A running basket total helps. A retail site may be able to comply by showing its delivery charges prominently and keeping a running total, including those charges, through the whole purchase.

Check every place a price appears in your sale: product and collection pages, banners, emails, social posts and ads.

4. The Price Marking Order: changes from 6 April 2026

The Price Marking Order 2004 covers goods (not services) sold by traders to consumers in Great Britain, online as well as in shops. Northern Ireland has its own order. Amendments made by the Price Marking (Amendment) Orders 2024 and 2025 took effect on 6 April 2026, after the start date was moved from 1 October 2025 (GOV.UK PMO guidance, SI 2025/592, SI 2024/1055). In short:

Selling price. Show the final price including VAT and all other taxes (SI 2024/1055).
Unit price, where needed. Goods sold from bulk, or that must be marked with a quantity (many pre-packed foods, drinks and toiletries, for example), generally need a unit price too, such as per kilogram, litre or item. The amended definitions set out which unit to use (GOV.UK guidance).
Online counts. Selling and unit prices are always required when an advert lets people buy at a distance, including goods sold directly online (GOV.UK guidance, paragraph 34).
Clear and legible. Prices must be unambiguous, easily identifiable and clearly legible, in a clear font of reasonable size. Delivery charges must be shown the same way.
Member or loyalty prices. If members pay less, show both prices (and unit prices where required), with the conditions, and don't give one set of prices more prominence than the other.
Promotions. The government asks traders to try to show unit prices for promotional items, including price reductions and multi-buys, to help people compare.

Breaking the order can be a criminal offence, and it can also be enforced through the civil consumer-law regime (GOV.UK guidance, Enforcement).

5. Countdown timers and “only 2 left”: urgency must be true

Falsely stating that a product, or a price, is available only for a limited time, to push people into deciding straight away, is banned outright (DMCC Act, Schedule 20, paragraph 7). The CMA's own example is a countdown clock that runs out, after which the offer carries on and the clock restarts. If the deadline is true, and a substantially similar offer doesn't reappear soon after, the CMA says that is unlikely to be a problem (CMA207, banned practice 7). Related bans include:

giving materially inaccurate information about market conditions or how available a product is, to get people to buy on worse terms (paragraph 20);
advertising a price when you have reasonable grounds to believe you won't be able to supply the product at that price in reasonable quantities, for a reasonable period, without saying so (paragraph 5);
claiming you are about to close down or move when you aren't (paragraph 17).

CTSI's guidance adds that a genuine end date is likely to be material information, so show it clearly. Avoid moving the end date once it's published, unless something you couldn't reasonably have foreseen happens (CTSI section 19). The CMA expects you to have evidence behind “selling fast” or “X people are looking at this” messages (CMA open letter).

6. Reviews: no fakes, no hidden incentives, no hiding the bad ones

Schedule 20, paragraph 13 bans (DMCC Act, Schedule 20, paragraph 13):

submitting, or commissioning someone else to submit or write, a fake consumer review, or a review that hides the fact it was incentivised. “Commissioning” includes incentivising by any means;
publishing reviews, or review information such as star ratings, in a misleading way. The Act's examples include suppressing negative reviews while publishing positive ones, giving positive reviews more prominence, and leaving out that a reviewer was paid or rewarded;
publishing reviews without taking reasonable and proportionate steps to prevent and remove fake reviews, hidden incentivised reviews and false or misleading review information.

This applies to reviews on your own site, so a review app you install for the sale is your responsibility. The CMA's fake reviews guidance (CMA208) explains the reasonable steps it expects. If you offer anything for a review, make sure the reward doesn't depend on what the review says, and that any incentivised review is clearly marked.

7. “Subscribe and save” and free trials: new rules from 2027

If your sale includes a subscription, free trial or auto-renewing plan, a new regime under Chapter 2 of Part 4 of the DMCC Act is on the way. It is not in force yet. The government says it will come into force in January 2027 (GOV.UK), and the draft Consumer Subscription Contracts (Cancellation and Information) Regulations 2026 give 1 January 2027 as their start date (draft regulations). The regime will require clear information before sign-up, reminders before trials and long contracts renew, an easy way to leave (online, if the customer signed up online) and a 14-day cooling-off period after a trial ends or a contract of 12 months or more auto-renews (GOV.UK). The Department for Business and Trade published business guidance on 19 October 2026 (GOV.UK subscription contracts guidance).

A subscription someone starts in a Black Friday sale will still be running in January, so it makes sense to plan your sign-up wording, reminder emails and cancellation route now.

8. Returns and refunds: the 14-day right to cancel

Most online sales to consumers come with a right to cancel under the Consumer Contracts Regulations 2013. The customer doesn't have to give a reason (regulation 29). For goods:

The period ends 14 days after the goods reach the customer (or someone they nominate, other than the carrier). For one order delivered in several parts, it runs from the last delivery (regulation 30).
If you don't tell people about the right to cancel as required, the period is extended by up to 12 months (regulation 31).
Refunds must be made without undue delay, and at the latest 14 days after you get the goods back or the customer shows they've sent them (if you haven't offered to collect). Refund the standard delivery cost too; if they paid for a pricier delivery, you only have to refund the cheapest common option you offered. Use the same payment method unless they agree otherwise, and don't charge a fee. You can deduct for loss in value caused by handling beyond what's needed to check the goods (regulation 34).
Exceptions include goods made to the customer's specification or clearly personalised, goods that deteriorate rapidly, and sealed hygiene items, recordings or software once unsealed (regulation 28).

Extended Christmas returns are a nice thing to offer, but don't present the legal 14-day right as if it were a special feature of your shop. Presenting consumers' legal rights as a distinctive feature of your offer is banned (Schedule 20, paragraph 11). Our print-on-demand guide covers the personalised-goods exception in more detail.

What we check, and what we don't

Our Website Compliance Check and Compliance Monitor test the parts of your website that sales campaigns most often break behind the scenes. New ad pixels, review widgets, pop-ups and countdown apps added for Black Friday can start setting cookies before anyone clicks “Accept”. We check:

Cookies and trackers that load before consent, and whether “Reject” actually stops them;
your privacy notice against UK GDPR Articles 13 and 14, and consent on sign-up forms;
company details (name, number and registered office) cross-checked with Companies House;
ICO registration, with a register lookup.

We don't audit your price history, delivery charges, timers, reviews or returns policy. Use sections 2 to 8 of this checklist for those. The Check report arrives within 2 working days, and the Fix Pack within 4 working days, so allow for that if you want fixes in place before your sale. The Monitor then re-checks your site every week, so a plugin added in December doesn't quietly undo the work.

Pre-sale checklist

Every “was” price is a genuine, recent selling price, charged for at least as long as the sale runs, and you have a dated record of it
No prices were raised before the sale to make the discount look bigger, and no lower price was charged in between
RRPs are labelled as RRPs and backed by evidence from your supplier
Headline prices include VAT and every mandatory fee; unavoidable delivery is in the total or clearly calculable
Unit prices are shown where the Price Marking Order requires them, in a clear, legible font
Any countdown or end date is true, shown clearly and not reset or quietly extended
Stock and demand messages (“only 2 left”, “selling fast”) are based on real data
No fake, bought or hidden-incentive reviews, no suppressed negative reviews, and a process to catch fakes
Subscription and free-trial sign-ups are ready for the new rules due in January 2027
Cancellation rights are explained before purchase; refunds go out within 14 days, including standard delivery
Extended Christmas returns are offered as extra, without presenting the legal 14-day right as a perk
New sale plugins, pixels and pop-ups don't set non-essential cookies before consent

Rhinehart Studio

Website Compliance Check · £79

An automated scan of up to 10 public pages, reviewed by a person, with a red/amber/green PDF report within 2 working days. It covers cookies and trackers before consent, whether “Reject” works, your privacy notice, sign-up form consent, company details against Companies House and ICO registration. Add the Fix Pack (£149) for paste-ready fixes and one re-scan, delivered within 4 working days. Then the Compliance Monitor (£19/month) re-checks your site every week and emails you what changed.

Get a £79 Compliance Check Keep watch with Compliance Monitor (£19/mo) Add the Fix Pack · £149

Fixed prices in GBP, paid securely via Stripe. The Monitor can be cancelled any time before your next billing date. Read more about the Check and the Monitor. We don't guarantee results, and our reports are not legal advice.

FAQ

How long must a product be at the “was” price before a sale?

UK law doesn't set a fixed number of days. The test is whether the comparison is genuine and not misleading. CTSI's guidance says a sale period longer than the time the product was on sale at the higher price is less likely to comply, and that recency, intervening prices and actual sales at the higher price all matter (CTSI pricing guidance).

Can I add a booking or service fee at checkout?

Not if every customer has to pay it. Mandatory fees are part of the total price and should be in the headline price from the start; adding them later is drip pricing (DMCC Act s.230, CMA209).

Is a countdown timer illegal?

No, if it is true. Falsely saying an offer is available only for a limited time, to rush people into a decision, is banned. A timer that resets, or an offer that carries on after the deadline, is the CMA's own example of what not to do (CMA207).

Do Christmas gifts get longer returns by law?

No. The legal right to cancel is 14 days after delivery for most online goods (regulation 30). Longer Christmas returns are a voluntary policy, and you shouldn't present the legal 14-day right as a special perk.

Will your check make my Black Friday sale compliant?

No. It is a technical review of your public website covering cookies, consent, your privacy notice, company details and ICO registration. It doesn't review your prices, timers, reviews or returns, it isn't legal advice, and no check can guarantee you won't receive a complaint or fine.

Official sources

Laws and guidance change. Check the sources above for the latest position. General information, not legal advice. For advice on your own circumstances, speak to a solicitor. Our check is a technical review of your public website and can't guarantee you won't receive a complaint or fine.

Black Friday and Christmas sales: the UK pricing rules online shops need to get right in 2026