A crossed-out price, a percentage discount and five stars next to a product can all encourage customers to buy. However, shoppers should know whether a promotion offers genuine savings and where the displayed reviews come from. The Omnibus Directive affects the daily operations of online stores in these areas: it increases transparency and restricts practices that mislead consumers.
For store owners, this means specific tasks involving pricing, marketing, reviews and the information available on their websites. These requirements should be considered both when building an online store and when developing an existing e-commerce business. Well-designed solutions help manage these obligations without manually updating every offer.
What Is the Omnibus Directive, and When Did the Changes Take Effect?
Omnibus is the commonly used name for EU Directive 2019/2161, which modernised consumer protection rules. In Poland, the key changes discussed here have applied since 1 January 2023. Businesses' obligations arise from national legislation implementing the directive, including the Polish Act on Price Information for Goods and Services and the Act on Combating Unfair Commercial Practices.
The rules also apply to small online stores. Using a popular e-commerce platform or a ready-made template does not automatically address every requirement. What matters is how the store actually presents its offers, runs promotions and provides information to customers. A review should therefore begin with the actual purchasing journey rather than simply checking the list of installed extensions.
The Lowest Price in the 30 Days Before a Reduction
The most widely recognised Omnibus obligation concerns how promotions are communicated. When a seller announces a price reduction, the promotional price should be accompanied by the lowest price charged for that product during the 30 days before the reduction was introduced. This allows shoppers to assess the offer against the prices previously charged by that store.
Comparing the new price with an arbitrarily selected regular price is therefore insufficient. Crossing out a higher amount may suggest savings that the customer is not actually receiving. At the same time, changing a price without announcing a reduction does not automatically trigger this disclosure requirement. The way the offer is presented matters, including labels that suggest a promotion.
New Products and Goods with a Short Shelf Life
If a product has been offered for less than 30 days, an announced reduction must show the lowest price charged between the start of its availability and the introduction of the reduction. A separate rule applies to goods that deteriorate quickly or have a short shelf life: the reference point is the price before the first reduction was applied. The pricing system should account for these differences rather than treating the entire catalogue identically.
How Should an Advertised Discount Be Calculated?
Suppose a product's regular price is PLN 200, but customers could buy it for PLN 160 during the 30 days before the promotion. The new promotional price is PLN 120. In this situation:
- the current selling price is PLN 120,
- the lowest price in the 30 days before the reduction is PLN 160,
- the reduction relative to that lowest price is 25%.
Advertising only a 40% discount calculated from the regular price of PLN 200 would communicate a different saving from the one established using the required reference price. An advertised reduction must be calculated relative to the lowest price in the 30 days before its introduction. The Court of Justice of the European Union also confirmed this in its judgment of 26 September 2024 in case C-330/23.
Omnibus Also Affects Advertising and Promotional Messaging
Information about the lowest price should accompany an announced reduction for a specific product wherever customers see that offer. In an online store, this means checking areas such as:
- product pages and product variant displays,
- category listings and search results,
- promotional sections on the homepage,
- banners, newsletters and advertisements featuring a specific discounted product.
The information must be readable and positioned close to the promotional price. Hiding it in the terms and conditions, using an unclear label or displaying text that is barely visible on a phone makes the offer harder to assess. Clear pricing information should be part of the website's design, just like an easy-to-use purchase button.
A discount code does not automatically exempt a promotion from these obligations. A publicly advertised campaign in which a code reduces the prices of specified products also requires an assessment of the rules on announcing reductions. Campaign planning should therefore cover the full advertising message, the conditions for receiving the discount and the price available after applying it.
Customer Reviews: Transparency and Authenticity
Reviews help shoppers assess product quality and customer service. Omnibus requires businesses displaying reviews to explain whether and how they check that the reviews come from people who purchased or used the product. This explanation should reflect the actual operation of the system rather than merely provide a reassuring statement on the website.
One possible approach is to link reviews to orders and send review invitations after a purchase. If the store also accepts comments without a confirmed transaction, it is useful to distinguish these situations clearly. A user being logged in does not, by itself, prove that they purchased the product they are reviewing.
The rules do not require every store to use one specific verification method. They require accurate information about the approach used. Publishing or commissioning fake reviews is prohibited, as is presenting reviews in a misleading way. Stores must also avoid labelling all comments as verified when appropriate checks have not been carried out.
Additional Information Requirements in E-commerce
Personalised Pricing and Contact Details
If a store personalises prices on the basis of automated decision-making, it must inform the consumer before they become bound by the contract. This may apply, for example, when an algorithm determines an offer for a particular person. Personalisation tools and marketing integrations should be reviewed with this requirement in mind.
The review of website information should also cover the business's identifying details, email address and telephone number, allowing customers to contact it quickly and efficiently. A contact form can be a convenient addition, but it does not replace all the required contact information.
Online Marketplaces and the Ranking of Offers
Additional obligations apply to online marketplaces where different sellers offer products. Customers should know whether they are entering into a contract with a business or an individual acting outside a business activity. The marketplace must also explain how responsibilities are divided between the platform and the seller, and inform customers that consumer protection rules do not apply when the seller is not a trader.
Transparency in search rankings also matters when customers search for products offered by different traders or consumers. Information must be provided about the main parameters determining the order of offers and their relative importance. Paid advertising or payments made to secure a higher position in search results should be clearly disclosed.
What Does Omnibus Mean for PrestaShop and WooCommerce Stores?
Meeting these obligations requires accurate information supported by correctly functioning software. For PrestaShop stores, it is worth checking whether the chosen module works with the theme, product combinations and the methods used to update prices. A similar review is needed for WooCommerce stores, particularly when prices are changed by additional plugins or an external system.
Displaying a lowest-price field is insufficient if the underlying data is incorrect. A good practice is to record changes made through the administration panel as well as imports, integrations and scheduled campaigns. For products with variants, check that the displayed price history corresponds to the option selected by the customer.
The solution should associate the reference price with the start of the particular reduction. This should not be assumed to mean a minimum recalculated every day over a rolling period. It is also worth preserving price history during migrations and making it possible to check where a displayed value came from. A newly installed extension cannot independently reconstruct earlier prices that the store never recorded.
Appropriately selected PrestaShop modules can improve store operations, but they require configuration and verification in the specific environment. Testing should also cover mobile devices, product listings and other places where promotions appear, rather than only a single product page on a desktop computer.
What Are the Potential Consequences of Non-compliance?
Breaches of the obligations set out in Poland's Act on Price Information for Goods and Services are subject to a fine of up to PLN 20,000, imposed by a regional inspector of the Trade Inspection. If a business breaches these obligations at least three times within a 12-month period counted from the first identified breach, the maximum fine is PLN 40,000.
Separately, for practices that infringe collective consumer interests, the President of the Polish Office of Competition and Consumer Protection (UOKiK) may impose a fine of up to 10% of the turnover achieved in the financial year preceding the year in which the fine is imposed. Beyond penalties, errors can lead to customer complaints, costly campaign corrections and a loss of trust. Accurate information makes offers easier to assess and reduces misunderstandings about prices and reviews.
How Can You Prepare Your Store to Meet These Obligations?
It is best to review the store before launching a major promotional campaign. The following sequence can help organise the work:
- Review promotional messaging across the store, newsletters and advertisements.
- Verify price history and the method used to determine the reference price.
- Test different scenarios, including variants, price imports, discount codes and successive promotional campaigns.
- Explain how reviews are published in a way that accurately reflects the procedures used.
- Check customer information and its readability on mobile devices.
The Omnibus Directive therefore affects more than a single message below a price. It requires consistency between offers, marketing and store functionality. If you are planning a new store or need changes to an existing solution, contact FriQ.Dev to discuss the technical work required. A well-prepared system makes it easier to run transparent promotions and manage everyday sales.
Sources and Legal Basis
- Polish Act on Price Information for Goods and Services - Articles 4 and 6.
- Polish Act on Combating Unfair Commercial Practices - information about reviews and search results.
- Guidance from the President of UOKiK on announcing price reductions.
- UOKiK - obligations concerning consumer reviews.
- UOKiK - information requirements for distance selling.
- UOKiK - rules on imposing penalties for consumer protection infringements.
- Court of Justice of the European Union - judgment in case C-330/23 on calculating advertised price reductions.