Black Friday pricing: what UK small online shops must get right in 2026

Black Friday is on 27 November this year, and for a small online shop the rush is rarely the hard part. The harder part is the pricing. Regulators have spent the past year making it very clear that a sale is not exempt from consumer law, and they now use automated tools to scan live adverts. This guide explains what the rules expect from a small seller, using the regulators' own published material and recent rulings, and what is worth doing in the next few weeks.

What has changed

The Digital Markets, Competition and Consumers Act 2024 gave the Competition and Markets Authority (CMA) the power to decide that a firm has broken consumer law and to fine it directly, without going to court. According to law firm Osborne Clarke, fines can reach 10% of global turnover. The CMA published final price transparency guidance and opened its first investigations into eight businesses, covering hidden fees, misleading time-limited offers and automatic opt-ins. It also sent advisory letters to 100 businesses about extra fees and online sales tactics.

Those are large firms, but the guidance is written for anyone who sells to consumers. Law firm commentary notes that the guidance is not itself law, yet it is where a regulator will start when judging your prices.

Rule one: show the total price

Where you invite someone to buy, the price shown must include every charge the customer cannot avoid. Osborne Clarke's summary of the CMA guidance makes these practical points:

• Mandatory charges, including delivery where it cannot be avoided, belong in the total price.
• Optional extras such as insurance, faster delivery or a donation need the customer's express consent. Pre-ticked boxes and other automatic opt-ins are not allowed.
• For a multi-item basket you can show the item price with a total that includes delivery, show the delivery charge and a running total, or build delivery into the price and call it free delivery.
• Information hidden behind an expandable panel or a separate page is not treated as reliable.

The enforcement so far shows how this plays out. Browne Jacobson reports that the CMA issued a final notice against AA Driving School and BSM Driving School over a mandatory £3 fee that was left out of the upfront price, with refunds of more than £760,000 and a fine reduced to £4.2 million. It also fined Marks Electrical £720,000 for automatically opting customers into extra services during the payment journey. A small shop will not face figures like these for a stray tick box, but the lesson is simple: check your checkout as a customer would.

Rule two: be able to prove your "was" price

This is where Black Friday catches people. In May 2026 the Advertising Standards Authority (ASA) upheld complaints against John Lewis, Boots, Debenhams and Very over savings claims, according to Lewis Silkin's write-up of the rulings. Some of the detail is useful for any shop:

• A Boots fragrance advertised as "was £80, now £60" was ruled misleading because the £80 price applied for only 21 days after launch, and the product then sold for less for longer.
• A Boots candle set was not misleading, because it had sold at the higher price for longer and in much greater volume than at the sale price. The same retailer, in the same ruling, had one claim upheld and one not.
• Very accepted its ads were wrong. Outdated "was" prices had stayed live through human error, and the ASA said that was no excuse.
• Debenhams could not rely on the argument that third-party sellers set the prices. Platforms are responsible for the savings claims in their ads.

The ASA applied the Chartered Trading Standards Institute's guidance on pricing practices. In practice, Lewis Silkin reports that the ASA expected documentary evidence such as daily prices over at least three months and the units sold at each price. A short period at a higher price just before a promotion does not establish a usual price. Browne Jacobson adds that the ASA uses an AI monitoring system to scan online savings claims, so you do not need a customer to complain for an advert to be looked at.

What to do before 27 November

None of this requires special software. A small shop can work through a short list:

• Export your price history. Pull the last three months of prices for every product you plan to discount, and the units sold at each price. A spreadsheet is enough.
• Only use "was" prices you can support. If the product was not usually sold at that price, show the sale price on its own, or describe the offer without a comparison.
• Do not raise prices to discount them. A temporary high price just before the event is the pattern regulators look for.
• Plan how old prices come down. Set an end date for each promotion in your shop platform so "was" prices disappear automatically. Very's problem was stale prices left live.
• Walk through checkout. Add one product, choose delivery, and look for charges that appear late and boxes that are already ticked.
• Check time-limited claims. If you say a deal ends at midnight, make sure it does. The CMA's investigations cover sales that did not end when advertised.
• Review marketplace listings. If you sell through a platform, check what comparison prices appear on your behalf.

Do not forget the scams

Black Friday brings fake shops and delivery scams, and your customers will be wary. The National Cyber Security Centre (NCSC) and the Home Office ran the Stop! Think Fraud campaign ahead of Black Friday last year. Its advice to shoppers includes reading reviews on trusted sites, turning on two-step verification for important accounts, checking out as a guest where possible, and pausing before clicking links in unexpected delivery messages. The campaign cites City of London Police data showing £11.8 million lost to online shopping fraud between 1 November 2024 and 31 January 2025.

You can make life easier for genuine customers. State clearly how and when you contact people about orders, and say that you will never ask for payment by bank transfer after checkout. Keep your shop software and plugins up to date as well.

The mood and the sensible response

The reaction to the ASA rulings has been mixed in tone but consistent in message. The ASA said the rulings send a clear message that promotional events are not exempt from the rules, and Which?, whose complaint led to the Very ruling, welcomed the action. Retail lawyers say that practices which were acceptable before the 2024 Act may no longer be. I found no public comment from small independent retailers, so treat the thresholds above as the regulators' expectations rather than a settled industry view.

The calm response is to keep records and keep claims modest. A plain, honest offer with a total price shown at every step is both compliant and easier for customers to trust. If your checkout or promotion tooling needs tidying up before the busy period, our ecommerce service covers exactly that kind of work.

This article is general information, not legal advice. For a specific promotion, check the CMA and Trading Standards guidance directly or take advice.