Guides · Your rights

UK pricing rules explained: CMA, DMCC Act and the ASA

What the law and the advertising codes say about sale prices, was-prices and ‘usual’ prices in the UK.

Updated 13 October 2026 · 4 min read · General information, not legal or financial advice.

When a shop advertises a discount in the UK, two overlapping sets of rules apply. Consumer protection law, enforced by the Competition and Markets Authority (CMA) and Trading Standards, makes misleading pricing unlawful. The advertising codes, enforced by the Advertising Standards Authority (ASA), set standards for how prices and savings are presented in ads. This guide explains both in plain English. It is general information, not legal advice.

The law: the DMCC Act 2024

The Digital Markets, Competition and Consumers Act 2024 (DMCC Act) replaced the older Consumer Protection from Unfair Trading Regulations 2008. The unfair commercial practices rules in the DMCC Act came into force in April 2025. They prohibit misleading actions and misleading omissions, including misleading information about price or the existence of a specific price advantage.

The biggest change is enforcement. The CMA can now decide for itself that consumer law has been broken and impose fines, rather than having to go to court first. Fines can reach up to 10% of a business’s global turnover. That gives retailers a much stronger incentive to get pricing right.

The Act also includes a list of practices that are always unfair, in Schedule 20. These include falsely claiming that a product or price is only available for a limited time to pressure you into deciding immediately, and giving materially inaccurate information about availability. We cover these in our guide to fake urgency.

The CMA’s reference pricing principles

In 2024 the CMA published principles for online mattress retailers on discount and reference pricing, following its work in that sector. The CMA said it will have regard to these principles when considering enforcement in other sectors too. The key points are:

• Genuine price. A was-price should reflect a price at which the product was genuinely sold.
• Immediately before. The higher price should apply immediately before the discount begins, on the same website.
• Duration. The product should have been offered at the higher price for a sufficient period. The CMA says compliance is more likely if that period is at least 30 days, and that the discount period should not be longer than the period at the higher price.
• Volume. Enough sales should have been made at the higher price. The CMA suggested sales during the higher-price period should not be less than half of sales during the discount period.

Both the duration and volume tests need to be met. Outsiders, including us, cannot see a retailer’s sales figures, so independent checks can only test the duration part.

The advertising codes: the ASA and ‘usual price’

The CAP Code, which the ASA enforces, requires marketers to make the basis of any price comparison clear and not to mislead. The ASA’s advice is that reference prices, whether shown as a crossed-out price, a “save £X” or a percentage off, must represent a genuine established usual selling price.

When judging what a usual selling price is, the ASA looks at evidence such as how long the product was on sale at the higher price, whether significant sales were made at that price, and how recent it was. Its published advice says it expects advertisers to provide at least three months of pricing history to assess the usual selling price. It has upheld complaints where a reference price had not been charged for a long time before the offer, where few units sold at the higher price compared with the discounted price, and where a “sale” ran much longer than the higher price had.

RRPs and ‘compare at’ prices

Comparisons with a recommended retail price are allowed, but they must not mislead. The CAP Code (rule 3.39) says comparisons with RRPs are likely to mislead if the RRP differs significantly from the price at which the product is generally sold, and the ASA’s RRP guidance says the fact that a manufacturer recommended a price is not enough on its own. The ASA also points marketers to the Chartered Trading Standards Institute’s Guidance for Traders on Pricing Practices. On 9 August 2026 the government announced a consultation, to launch in the autumn, on whether fake “was” prices, invented discounts and misleading RRPs should be added to the list of practices banned under the DMCC Act.

Other pricing rules worth knowing

• Drip pricing. Under the DMCC Act, mandatory fees that you cannot avoid should be included in the headline price rather than revealed later in checkout.
• Unit pricing. Groceries generally need to show a unit price (for example per kg or per litre) so you can compare pack sizes.
• Fake reviews. Commissioning or publishing fake reviews is now on the banned list in Schedule 20.

What this means for you

You do not need to memorise any of this. The practical takeaway is that a UK was-price should be a recent, sustained, genuine price. If price history shows it was only charged briefly, or long ago, you are entitled to be sceptical. You can complain to the ASA about an ad, or report a trader via Citizens Advice.

Sources

• DMCC Act 2024 (legislation.gov.uk)
• DMCC Act Schedule 20: practices always considered unfair
• CMA: Unfair commercial practices guidance (CMA207)
• CMA: Discount and reference pricing principles
• ASA: Promotional savings claims
• ASA: Making price comparisons with previous prices
• ASA: Prices: Recommended retail prices (RRPs)
• GOV.UK: PM starts roll out of ‘everyday fixes’ on the cost of living (9 August 2026)

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