Price Reductions & 'Was/Now' Pricing Claims Compliance Check

Why this matters

Almost every UK retailer and online seller uses price reductions, ‘was/now’ comparisons, ‘sale’ banners or ‘up to 50% off’ claims. Since 6 April 2025, the Digital Markets, Competition and Consumers Act 2024 (DMCC Act) has replaced the Consumer Protection from Unfair Trading Regulations 2008 with a direct ban on unfair commercial practices, including misleading actions and omissions about price. A reference price that was never genuinely charged, or was only charged briefly to make a later discount look bigger, can mislead consumers into buying. The Price Marking Order 2004 separately requires that selling prices are clearly displayed and unambiguous.

The big change is enforcement: the Competition and Markets Authority can now investigate and fine businesses directly, without going to court, with penalties of up to 10% of global annual turnover for consumer law breaches. Trading Standards retain their existing powers too. The CMA and Trading Standards have both signalled that misleading price promotions are an enforcement priority, and the CMA’s pricing practices guidance expects that any ‘was’ price should be a genuine price at which the product was actually offered for a meaningful period. Small businesses are not exempt, so it is worth checking your promotion practices before your next sale event rather than after a complaint.

What you'll need

• Whether you show 'was', 'RRP', 'now' or percentage-off prices anywhere (shop, website, marketplace, email)
• Whether you can evidence the previous price and how long it was charged
• How often and how long your sales and promotions run
• Whether you use 'up to', 'from' or 'save' claims in advertising
• Who in your business approves prices and promotional wording

What you'll get

A personalised compliance report covering: a score out of 100, an executive summary, a list of findings ranked by severity, and a prioritised action plan with timeframes.