Pricing transparency is tightening (2024–2026): discounts + fees rules across EU/Germany/UK/US — what to track

If you run a webshop in 2026, “price” is no longer just the number on the product page.

Across major markets, regulators are converging on the same idea:

• Discounts must be genuine (no inflated “was” prices).
• Mandatory charges must be clear (no surprise fees later in checkout).

For competitor tracking, that means: if you only store a sticker price, you’ll miss the mechanics that are increasingly regulated and increasingly important for conversion.

EU + Germany: discount rules are about the “prior price”

In the EU, the “Omnibus” changes added Article 6a to the Price Indication Directive. The practical effect: when you announce a price reduction, the reference “prior price” is generally the lowest price in the previous 30 days (with some exceptions, e.g., perishable goods). The European Commission also published guidance on how to interpret and apply Article 6a.

Germany implements this via Section 11 PAngV, which requires showing the lowest price applied in the last 30 days when advertising price reductions.

What to track (EU/DE discounts)

To correctly interpret competitor discounts, capture:

1. Current price
2. Prior-price reference (30-day low)
3. Discount claim type
   • “-20%”, “was/now”, strike-through price, voucher-only, member-only, etc.
4. Start/end of promo window
5. Product condition
   • perishable/fast-expiring (rules can differ)

UK: drip pricing and “partitioned pricing” are in the spotlight

The UK CMA published price transparency guidance (CMA209) that explicitly covers:

• what must be included in price information (mandatory fees/charges),
• drip pricing (adding mandatory charges later),
• partitioned pricing (splitting price components without making the total clear).

What to track (UK fees)

1. Displayed price
2. Mandatory charges surfaced later
3. Where the charges appear
   • PDP, cart, checkout step N
4. Total price at each step (a timeline is gold for analytics)

US: fee transparency enforcement is real (even if scope varies)

The FTC’s Rule on Unfair or Deceptive Fees (commonly framed as targeting “junk fees”) aims to prevent practices that hide the total price via mandatory fees. The FTC’s FAQs clarify what can (and can’t) be excluded from the “total price” in the initial disclosure.

What to track (US fees)

1. Total mandatory charges you can calculate upfront
2. Any “service” or “processing” fee patterns
3. Which categories add fees and when (cart vs checkout)

The Trackabl “offer snapshot” (works across markets)

If you want alerts that reflect reality, store a minimal offer snapshot:

• Base price
• Prior price (if discount claim exists)
• Coupon prompts / voucher mechanics
• Shipping + free-shipping threshold
• Mandatory fees (and where they appear)
• Delivery ETA
• Availability

Then compute:

Effective price = base price + shipping + mandatory fees − discounts

…and emit alerts people actually understand, like:

• “Effective price -5% (fee removed)”
• “Discount claim changed (prior price updated)”
• “Same price, but delivery got faster (pressure increasing)”

Takeaway

Pricing transparency rules aren’t just legal trivia — they define the competitive playing field.

Track the offer, not just the sticker price, and your intelligence will stay useful across EU/Germany/UK/US in 2026.