Black Friday rules UK businesses must follow in 2026: discounts, was prices, countdown timers and the new fines

TL;DR: There is no special Black Friday law, but every discount you advertise must be genuine. A was price should be a recent price you really charged, an up to claim needs a significant share of items at that saving, and a deadline must be real. Since 6 April 2025 the CMA can fine a business up to 10% of its worldwide turnover without going to court first.

Key takeaways

• The Black Friday rules UK businesses must follow are ordinary consumer law. No special law covers Black Friday on 27 November 2026 or Cyber Monday on 30 November, but every discount you advertise must be genuine.
• Since 6 April 2025, the Digital Markets, Competition and Consumers Act 2024 lets the CMA decide breaches itself and fine a business up to 10% of its worldwide turnover.
• A was price should be a price you charged recently, and for at least as long as the sale runs. Trading Standards guidance updated in April 2026 sets out the tests.
• An up to 50% off claim needs a significant proportion of the items in the sale at 50% off, according to the ASA.
• Falsely telling customers an offer ends when a countdown clock runs out is a banned practice, and Emma Sleep was found by the High Court in May 2026 to have used misleading timers.
• Customers who buy online keep their right to cancel within 14 days of delivery, sale or no sale.

Black Friday deals are where many small shops make their biggest price claims of the year, and where the regulators look hardest. The rules have also changed. Since April 2025 the Competition and Markets Authority can fine a business directly for misleading prices, and in November 2025 it opened a drive on online pricing that named countdown timers and pressure selling.

This guide sets out the Black Friday rules UK businesses must follow in 2026, in plain terms: when a was price is genuine, what up to claims have to mean, when a countdown timer breaks the law, and what to check before your sale goes live. It draws on the CMA’s guidance, the ASA’s Black Friday advice and the Trading Standards pricing guidance updated in April 2026.

What are the Black Friday rules UK businesses must follow?

There is no separate Black Friday law. The same consumer law applies all year: the Digital Markets, Competition and Consumers Act 2024 bans misleading prices and fake urgency, the CAP Code that the ASA enforces covers your adverts, and online sales carry a 14-day right to cancel. On Black Friday, more of your claims are tested at once.

The test behind most of these rules is whether a claim would mislead the average consumer, whom the CMA’s unfair commercial practices guidance describes as reasonably well informed, reasonably observant and reasonably circumspect. A claim that would lead that person to buy something they otherwise would not is where the trouble starts.

Three bodies matter for a small business. The CMA enforces consumer law nationally, your local Trading Standards service enforces it locally, and the Advertising Standards Authority rules on adverts, including your website, emails and social posts.

What changed in 2025 and 2026?

The biggest change to the Black Friday rules UK sellers face is enforcement. The unfair commercial practices rules in the DMCC Act apply to anything a business does from 6 April 2025, and the government’s summary for businesses says the CMA and the courts can now fine traders who break them up to 10% of their worldwide turnover.

The CMA has used the powers quickly. On 18 November 2025 it opened investigations into 8 businesses and wrote to 100 more across 14 sectors, including homeware, fashion, gyms, cinemas, food delivery and online vouchers, about drip pricing, pressure selling and misleading countdown timers. By May 2026 it had opened investigations into 14 businesses and closed its case against the AA with £4.2 million in fines and £760,000 in refunds.

The pricing guidance changed too. The Chartered Trading Standards Institute reviewed its Guidance for Traders on Pricing Practices in April 2026 and withdrew earlier versions. It is advisory, and only a court decides whether the law was broken, but it is the clearest statement of what Trading Standards expects from a price comparison.

When can you say was £X, now £Y?

You can show a was price when it is a price you genuinely charged, recently, for a meaningful period. The Trading Standards guidance asks how long the product sold at the higher price compared with how long the comparison runs, and how recently the higher price was charged. A comparison that runs longer than the higher price did is less likely to comply.

The guidance gives a worked example. An online retailer that shows was £500, now £350 for a month, after selling the product at £500 for the previous month with no other promotions running, is the kind of comparison it calls more likely to comply. A website quoting a price it last charged many months ago is the opposite case.

The ASA’s Black Friday and Cyber Monday tips point the same way. The sale price should not be available for longer than the usual selling price, the comparison should be against the most recent price, and pricing history and sales data are what the ASA looks at when a claim is challenged. Keep that evidence for every was price you show.

The common trap is the price raised for a short time before November so that a bigger saving can be shown afterwards. Under both sets of guidance, a higher price charged briefly, and long before the comparison runs, gives a weak basis for a saving.

What do up to and from claims have to mean?

An up to claim needs real items at the headline saving. The ASA expects a significant proportion of the items included in the sale to be discounted by the percentage in the headline, and a from £X claim needs a significant proportion of items available at £X. A sale where one item reaches 50% off and the rest get 10% should not lead with up to 50%.

Discount claims with all or everything carry more risk. The ASA says a qualification that excludes items is likely to contradict a headline claim of everything, and that combined claims need evidence that all items had some element of reduction. The Trading Standards guidance adds that general notices such as Up to half-price sale must reflect the reality of the offer.

Can you use a countdown timer on Black Friday?

Yes, if the deadline is real. Falsely telling a customer that an offer will end when a countdown clock runs out is a banned practice under the DMCC Act, which means it is unfair in every case, with no need to prove its effect on shoppers. A timer that counts down to a real end date, after which the price really goes up, is not a problem in itself.

The CMA’s guidance gives that exact example. The government’s summary for businesses puts it more simply: you must not pretend that a special offer will finish soon when this is not true. The ASA adds that promotions should not normally be extended beyond their closing dates, and the Trading Standards guidance says to avoid changing an end date unless something happens that could not reasonably have been foreseen.

The case to learn from is Emma Sleep. On 28 May 2026 the CMA announced a High Court order, made on 22 May, confirming that the mattress seller had behaved illegally with misleading countdown timers, false high demand messages and discount claims. That case started under the old law, before the CMA could fine.

In practice: set the end date before the sale starts, show it in the first advert, and let the offer end when it says it will. Do not reset countdown timers for each visitor, and do not follow one deal with a near identical one the next morning.

How should you show an RRP or an introductory price?

An RRP comparison needs evidence that the recommended price is what retailers generally charge. The ASA says an RRP should be the price recommended by the manufacturer and at which retailers generally sell those goods across the market, and that the manufacturer’s website alone, or with only one retailer, will not be sufficient evidence.

The Trading Standards guidance says that when you compare with an RRP, you should tell customers clearly and prominently that the higher price is an RRP, and that an RRP must not be false. Do not write was £99 when £99 is the maker’s recommended price and you have never charged it yourself.

Introductory prices follow a similar logic. The ASA says they must be clearly described as introductory, and the Trading Standards guidance says the practice is likely to be unfair if the price does not go up when the introductory period ends.

What about stock limits, terms and free gifts?

The ASA expects you to estimate demand before a promotion and to be able to show that you did. If a deal has a limit, say what it is, because subject to availability might not be enough. If stock runs out, tell customers during the promotion, since a statement after it has ended will not be sufficient.

Significant terms belong in the first advert, not a page away. The ASA lists the start and end dates as significant conditions to state up front, along with the nature and number of any prizes or gifts. Its own advice for doubtful cases is short: if in doubt about whether a term or condition is significant, put it in.

Do Black Friday prices have to include every fee?

Yes. The price you show must be the total price, including any compulsory charges, which ends drip pricing such as a booking fee added at checkout. Optional extras can stay optional, but a charge every customer must pay belongs in the headline price.

This applies all year, and Black Friday adverts put it to the test because the headline price is the whole message. Our guide to total price rules and drip pricing explains what counts as a compulsory charge and how to show delivery costs. The CMA published its final price transparency guidance on the same day as its November 2025 pricing drive.

What about reviews and high demand messages?

Fake reviews are banned outright. Writing or commissioning a fake consumer review is one of the banned practices in the DMCC Act, and the government’s summary says that if you publish consumer reviews, you have to take appropriate steps to make sure they are genuine. A Black Friday product page showing hand-picked or invented reviews breaks consumer law, whatever the price.

High demand messages fall under the same idea as countdown timers. A line such as 12 people are viewing this item is fine if it is true and current. Emma Sleep’s false high demand messages were part of what the court found illegal in May 2026.

Can customers return items bought in a Black Friday sale?

Yes. A sale price does not change the right to cancel an online order. The government’s guide to online and distance selling says you must tell customers they can cancel their order up to 14 days after it is delivered, and some exemptions apply, such as goods and services worth £42 or less.

A shop’s own returns policy can be more generous, and many extend returns over Christmas, but it cannot be less generous than the law. Faulty goods are a separate right that also survives any sale. Our guide on how to start an online shop in the UK covers the distance selling rules in more detail.

What happens if you break the rules?

The CMA can now decide a case itself and fine a business up to 10% of its worldwide turnover for breaking consumer law, and it can make you refund customers. Most banned practices are also criminal offences: the CMA’s guidance says a conviction in the Crown Court can bring a fine, up to two years in prison, or both.

For most small businesses the first problem is more likely to be an ASA ruling or a letter from Trading Standards than a fine. An ASA ruling is published with your business name on it, and the ad has to come down. Either way, putting a discount right after a complaint costs more than getting it right before the sale starts.

Your Black Friday checklist

These checks cover the Black Friday rules UK shops trip over most. Run through them before your Black Friday deals go live, on your website, in your emails and on social media:

1. For every was price, confirm when you last charged it and for how long, and keep the price history and sales data.
2. Make sure a significant share of the items in the sale reach any up to saving you advertise.
3. Fix the start and end dates now, show them in the first advert, and do not extend the sale.
4. Point any countdown timer at the real end date, the same for every visitor.
5. Label RRPs and introductory prices clearly, and keep evidence that an RRP is a real market price.
6. Estimate stock for each deal, state any limits, and tell customers during the sale if something sells out.
7. Show total prices with every compulsory fee included.
8. Check that your returns page still offers at least the legal 14 days for online orders.
9. Remove any review you cannot show came from a real customer.

Frequently asked questions

Is Black Friday regulated in the UK?

Not by a law of its own. Black Friday deals follow the same consumer law as any other sale: the DMCC Act 2024, the CAP Code enforced by the ASA, and the Consumer Contracts Regulations for online orders. What changes is the volume of price claims that regulators and shoppers check at once.

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

There is no fixed number of days in the law. Trading Standards guidance asks whether the higher price was charged recently, and for at least as long as the sale runs. Its example of a comparison more likely to comply is a month at £500 followed by a month at £350.

Can I extend my Black Friday sale if it goes well?

Avoid it. The ASA says promotions should not normally be extended beyond their closing dates, and the Trading Standards guidance says to change an end date only for reasons that could not reasonably have been foreseen. Falsely saying an offer will end soon is a banned practice.

Are countdown timers illegal in the UK?

Not when they count down to a real deadline. A timer becomes illegal when the offer does not actually end when the clock runs out, for example when it resets for each visitor. The CMA named misleading countdown timers in its November 2025 pricing drive.

Can customers return Black Friday purchases?

Yes. Customers who buy online can cancel within 14 days of delivery under the Consumer Contracts Regulations, whatever the price, with some exemptions. Faulty goods carry separate rights. A sale does not remove either right.

What is the fine for misleading prices in the UK?

Since 6 April 2025 the CMA and the courts can fine a business up to 10% of its worldwide turnover for breaking consumer law. Most banned practices are also criminal offences, with fines and up to two years in prison on conviction in the Crown Court.

Selling online this Christmas?

We build websites and online shops for UK small businesses from £300 a year per site, including hosting, your domain and five pages, with one fixed price in writing before work starts. See our online shop service, or start with a free website check before your sale goes live.