Was Prices And RRPs

The Short Version

The CMA's price transparency guidance says misleading reference pricing is outside its scope, and points to the CMA's general guidance on misleading actions and omissions (CMA207, chapters 5 and 6) and to advertising guidance from CAP, the body that writes the advertising rules the ASA enforces. The ASA and CAP advice below is the most detailed official guidance we found. Some of it was written before the 2025 changes to the law, so treat it as a guide to what regulators look at.

"Was" Prices: Four Questions

CAP says price comparisons with a previous price must make the basis of the comparison clear (CAP Code rule 3.39). It sets out four considerations:

1. Recency. Was the higher price charged recently? In one ruling a necklace had not sold at the reference price for at least 12 months.
2. Duration. Was the higher price charged for longer than the promotional price? One laptop sale ran for 32 days against a 21-day reference period, and was found misleading.
3. Sales volume. Did a significant number of sales happen at the higher price? One advertiser had seven units at the reference price against 74 at the discount.
4. Sales channel. Was it the usual price in the same channel the advert suggests, such as online or in store?

RRPs

• A manufacturer's RRP alone is not enough. You may need to show the product was generally sold at that price.
• If you set the price yourself, CAP suggests "Was £x, now £x" rather than calling it an RRP.
• Do not use an RRP for a product that has not launched. CAP suggests an "introductory" price.
• Keep sales and price data, and evidence from other retailers. CAP's page says a few selective examples were not enough in some rulings.

What May Change

GOV.UK says a consultation is planned this autumn on whether fake "was" prices, invented discounts and misleading RRPs should be added to the list of banned practices. That is a plan, not law. We will update this page when the position is clear.

What We Do

SiteAudit flags crossed-out prices that may be hard to support and asks you to show the price history behind them. We cannot see your sales data unless you share it.

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