A homeware merchant ran an August bank-holiday sale: a jug set went from 89 euros down to 59 euros, banner screaming '34% off.' Four days later a competitor filed a complaint with the national consumer protection authority, because the jug had only ever been listed at 69 euros for the three weeks before the sale — the 89 euro anchor price hadn't existed in the last 30 days. That's not a hypothetical; it's the single most common Omnibus Directive violation consumer authorities flag, and it's avoidable with about ten minutes of configuration.
What the Omnibus Directive Actually Changed
Directive (EU) 2019/2161 — commonly called the Omnibus Directive — amended several existing EU consumer protection laws and has applied since 28 May 2022. It isn't new anymore, but enforcement has picked up sharply as national consumer authorities finish building the tooling to detect violations at scale, which is why merchants who treated it as a 2022 checkbox are getting caught out now.
Four changes matter most for a PrestaShop store.
1. Price reduction transparency
When you advertise a price reduction, you generally must display the lowest price you charged for that product in the 30 days immediately before applying the reduction. It doesn't matter what the item's highest-ever price was, or what you'd like the discount to look like — the reference point is the actual lowest price charged in that rolling window. Some member states apply nuances for perishable or short shelf-life goods, so check your local transposition if you sell those categories.
2. Fake and unverifiable review rules
You can't claim reviews are from genuine purchasers without taking reasonable steps to verify that. Buying reviews, commissioning someone to write them, or submitting your own under a customer's name is banned outright, as is materially distorting review rankings to hide negative feedback.
3. Ranking parameter transparency
If your site presents ranked search results in response to a query — a marketplace, a category page with a 'best match' sort, anything similar — you need to disclose the main parameters that determine ranking and their relative importance, and clearly label any paid placements that sit inside otherwise organic-looking results.
4. Personalised pricing disclosure
If a price is set through automated decision-making based on a consumer's personal data — browsing history, past purchase behaviour, that sort of signal — rather than shown identically to everyone, you must inform the consumer clearly before they complete the purchase.
Penalties also got teeth: national authorities can now impose fines up to 4% of a trader's annual turnover in the member state concerned, a significant jump from the low, inconsistent penalties that applied before.
Price Display: Before and After
| Scenario | Non-compliant approach | Omnibus-compliant approach |
|---|---|---|
| Flash sale on an 89 euro item now 59 euros | Show 'was 89 euros' if that price was never actually charged recently | Show the lowest price charged in the 30 days before the reduction, even if that's 69 euros |
| Gradual multi-step discount | Reset the 'was' price after every markdown so each step looks bigger | Reference the lowest of all prices shown across the rolling 30-day window |
| Customer reviews | Publish every submitted review, including unverified or incentivised ones, without disclosure | Only mark reviews 'verified buyer' if you actually check the reviewer purchased the item |
| Category search results | Blend sponsored listings into results with no distinction | Label paid placements and publish your main ranking criteria in an accessible policy |
Where PrestaShop Stores Get This Wrong
The most common gap isn't malicious — it's a pricing module that only stores the current price and the price at the moment of the last change, not a rolling 30-day history. When a merchant manually sets a 'compare at' price for a promotion, there's nothing stopping them from typing in an inflated number that has no basis in the last month's actual pricing. Reviews modules have a similar problem: many display every submitted review as if it carries equal weight, with no purchase-verification step and no label distinguishing verified from unverified feedback. And plenty of stores with a marketplace-style 'best match' or 'popularity' sort have no published explanation of what that sort actually weighs, which is exactly the transparency gap the directive targets.
For a broader view of how this fits with everything else on your compliance list, see our complete EU compliance checklist and our guide to the Digital Services Act, which adds its own marketplace transparency duties on top of these.
Omnibus compliance checklist
- Install or configure a price-history mechanism that stores the lowest price for the previous 30 days for every product, not just the price at last change
- Audit any current or planned promotional banners against actual 30-day price history before publishing
- Configure your reviews module to distinguish verified-purchase reviews and stop presenting unverified reviews as if they were confirmed
- Publish a short ranking-and-sponsored-content policy if your store has a marketplace or search feature, and label any paid placements clearly
- Document whether any dynamic or personalised pricing logic runs on your store, and add a clear disclosure at the point of sale if it does
- Keep records of price history and review moderation decisions for the retention period your national authority expects, in case of an audit
Getting Omnibus-ready this quarter
Pull the price history for your last three promotional campaigns and check the 'was' price against the lowest price actually charged in the 30 days before each one — that single audit catches the most common, and most fined, Omnibus violation before a competitor or authority does it for you. For the product-safety side of EU compliance, our product safety compliance checklist covers the other set of listing requirements you'll want alongside this one.
Frequently asked questions
What is the Omnibus Directive and when did it start applying?
It's Directive (EU) 2019/2161, which amended existing EU consumer law and has applied across the EU since 28 May 2022. It's often confused with newer rules, but it's been enforceable for years — recent enforcement has simply intensified.
What exactly is the 30-day lowest price rule?
When you advertise a price reduction, you must show the lowest price you charged for that product in the 30 days immediately before the reduction, not an inflated 'was' price that was never recently charged.
Do fake review rules mean I can't use a reviews plugin?
No, but you can't present reviews as verified purchases unless you've taken reasonable steps to confirm the reviewer actually bought the product, and you can't buy, write, or commission fake reviews.
What counts as personalised pricing that needs disclosure?
Any price set through automated decision-making based on a consumer's personal data, such as browsing behaviour or purchase history, rather than a price shown identically to everyone, generally needs a clear disclosure before checkout.
How big are the penalties for non-compliance?
Member states can now impose fines up to 4% of a trader's annual turnover in the relevant country, a significant increase from the low, inconsistent penalties that applied before the Omnibus Directive.
Does the 30-day rule apply to every kind of discount?
It applies to advertised price reductions generally, though some member states have specific rules for perishable or short-shelf-life goods and for gradually reduced prices, so check your national transposition for edge cases.
Related reading
- Digital Services Act Explained for Merchants
- Understanding GPSR Requirements
- Complete EU Compliance Checklist for Online Stores
- Digital Markets Act: Does It Affect Your Store?
- Product Safety Compliance Checklist
