Black Friday falls on Friday 27 November 2026, with Cyber Monday following on 30 November. For a lot of online stores, it’s the busiest few days of the year.
It’s also the time when the pressure to squeeze out every last sale is highest. Countdown clocks go up, “was” prices appear next to every product, and delivery charges quietly turn up at the last step of checkout.
This year, some of those habits carry real risk. Under the Digital Markets, Competition and Consumers Act 2024, the Competition and Markets Authority (CMA) can now investigate and fine businesses directly for misleading pricing, and it has made it clear that hidden fees and fake urgency are high on its list.
The good news? The things that keep you on the right side of the rules are the same things that make shoppers trust you enough to buy. Here’s what to check before your sale goes live.
What Changed, in Plain English
Misleading prices have been illegal in the UK for a long time. What changed is how the rules are enforced.
Since April 2025, the CMA has had the power to decide for itself whether consumer law has been broken and to issue penalties of up to 10% of a business’s global turnover, without first going through the courts. In November 2025 it published its final price transparency guidance and opened its first investigations, focusing on two practices in particular:
- Drip pricing: showing a headline price and then adding compulsory charges later in the checkout.
- Pressure selling: countdown timers or “last chance” messages that suggest urgency when the offer isn’t genuinely time-limited.
The first cases involved large companies, including ticketing sites, driving schools and retailers. But the guidance applies to any business that advertises prices to consumers, whatever its size. The CMA also sent advisory letters to around 100 other businesses, which tells you it’s watching the wider market, not just the biggest names.
1. Show the Full Price Upfront
The core principle of the guidance is simple: when you show a price, it should include every charge the customer can’t avoid.
That means compulsory booking fees, service charges, admin fees or “processing” fees belong in the headline price, not in a line that appears at the final step.
Imagine a candle shop advertising a gift set at £24, then adding a mandatory £2.50 “packaging fee” on the payment page. The shopper hasn’t been given the real price until they’re almost committed. That’s exactly the pattern the CMA is targeting.
Delivery is treated slightly differently. If the delivery cost depends on things you can’t know in advance, such as where the customer lives, you can explain that delivery will be added and make it clear how it’s calculated. What you shouldn’t do is leave customers to discover delivery costs for the first time at checkout. The guidance walks through how mandatory, optional and variable delivery charges should be shown, so it’s worth reading the section that applies to your store.
The fix: Add a test product to your basket and go all the way to the payment step. If the total you pay is higher than the price you first saw, and the difference isn’t optional or explained upfront, change it before Black Friday.
2. Only Use Countdown Timers That Tell the Truth
Countdown timers work because they create urgency. That’s also why they’re under scrutiny.
A timer is fine if the offer genuinely ends when the clock hits zero. It becomes a problem when:
- The timer resets every time someone reloads the page.
- The “sale ends tonight” banner is still there the following week.
- The same price is available after the deadline, or is reintroduced a few days later as a “new” offer.
- Stock warnings like “only 2 left” aren’t based on your actual stock levels.
Many countdown apps and plugins have an “evergreen” or looping mode designed to restart automatically. If yours does, it’s worth switching it off.
The fix: Decide your sale dates before you build anything. Set your timers to those dates, then make sure prices actually change back when the sale ends.
3. Make Your “Was” Prices Genuine
“Was £80, now £40” is one of the most persuasive messages in retail. It only works, legally and commercially, if the £80 was real.
A reference price shouldn’t be a figure the product was briefly listed at to make the discount look bigger, or a price it hardly ever sold at. Consumer law treats misleading price comparisons as an unfair commercial practice, and the CMA’s unfair commercial practices guidance covers how comparisons should be presented.
Shoppers are getting better at spotting inflated discounts, too. Price-tracking tools and browser extensions make it easy to check whether that “50% off” is really a discount at all. If the claim doesn’t stand up, you’ve lost more than a sale. You’ve lost trust.
The fix: Keep a simple record of what each discounted product has actually sold for over the past few months. If you can’t support a “was” price, use a different message, such as “Black Friday price” or “Save £10 this weekend”.
4. Don’t Pre-Tick the Extras
Gift wrapping, extended warranties, priority dispatch and donations can all be useful add-ons. But they should be things the customer chooses, not things they have to spot and remove.
Automatically opting customers into optional charges was one of the practices the CMA flagged in its first round of investigations, and it has published separate guidance on getting consent for additional charges online.
The fix: Look at every checkbox and toggle in your basket and checkout. If anything that costs money is already selected by default, untick it.
Getting traffic but not enough enquiries?
Your website could be losing customers at points in the journey. Use our free Conversion Rate Audit Checklist to find the friction and prioritise what to fix.
5. Make Sure Your Returns Information Is Easy to Find
Black Friday brings in a lot of first-time customers. They don’t know you yet, so they’re more likely to look for reassurance before they buy.
Your returns and delivery information is part of that reassurance. If it’s buried in a footer link or written in dense legal language, hesitant shoppers may simply go elsewhere. We’ve written before about how a clear returns policy can even affect whether AI shopping tools recommend your store, so the benefit goes beyond the sale itself.
The fix: Add a short, plain-English summary of delivery times and returns near the “Add to basket” button, with a link to the full policy. If your returns window is different for sale items, say so clearly.
Honest Doesn’t Mean Boring
It’s easy to read all of this and think the rules have taken the fun out of Black Friday. They haven’t. You can still create genuine excitement:
- Real deadlines: A sale that genuinely ends at midnight on Cyber Monday is urgent on its own.
- Genuinely limited stock: If you only have 50 gift boxes, say so, and show the real number.
- Early access: Offering your email subscribers first access to the sale rewards loyalty without inventing pressure.
- Bundles and gifts with purchase: These add value without relying on an inflated “was” price.
And if you’re still deciding whether a big discount event suits your brand at all, our guide on whether every business should join the Black Friday frenzy is worth a read. Service businesses can also find ideas in our post on optimising landing pages for holiday traffic.
The Takeaway
The pricing rules aren’t asking you to stop selling. They’re asking you to be clear about what you’re selling and what it costs.
That’s also what customers want. A shopper who sees the full price upfront, trusts your discount and knows how returns work is far more likely to complete their order, and to come back after the sale is over.
This article is general guidance, not legal advice. If you’re unsure how the rules apply to your pricing, the CMA’s guidance is the best starting point, and a consumer law specialist can advise on your specific situation.
Your Pre-Sale Pricing Check
Before your Black Friday offers go live, run through your own checkout as if you were a customer and ask:
- Is the price I see first the price I actually pay, apart from genuinely optional extras?
- Is it clear how delivery is charged before I reach checkout?
- Does every countdown timer match a real end date?
- Can I back up every “was” price?
- Is anything that costs extra already ticked?
- Can I find the returns policy in one click?
If you answer “no” to any of these, you’ve found your first job for this week. For a wider look at what stops visitors buying, see our list of conversion problems to fix.
Need Help Improving Your Website?
Get expert Website support, optimized designs, and actionable marketing insights.
