The digital marketplace is evolving – and so is European law. Since the introduction of the EU Omnibus Directive, businesses selling to consumers across the European Union must meet new standards of transparency, especially when it comes to displaying prices, handling customer reviews, and disclosing who is behind a sale. Whether you’re a growing e-commerce brand, a large online marketplace, or a cross-border retailer, it’s vital to understand what the Omnibus Directive means in practice – and how to stay compliant.
What is the Omnibus Directive and why was it introduced?
The Omnibus Directive (EU Directive 2019/2161) is a legislative update designed to strengthen consumer protection across the EU single market and to adapt existing laws to the realities of digital commerce. It amends four key directives:
- Consumer Rights Directive
- Unfair Commercial Practices Directive
- Unfair Contract Terms Directive
- Price Indication Directive
Its goals are clear: to increase price transparency, tackle deceptive practices (like fake discounts or reviews), and ensure that consumers shopping online receive the same protection as those in traditional retail settings.
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The directive came into force on January 7, 2020, with member states required to transpose it into national law by May 28, 2022. Most EU countries – including Germany, France, Spain, and Poland – have since implemented local regulations reflecting these changes.
Price reductions: what’s the “lowest price in the last 30 days” rule?
One of the most impactful provisions of the Omnibus Directive relates to price reduction announcements. Under the new rules, whenever a business advertises a discount on a product, it must also clearly display the lowest price charged for that product in the 30 days prior to the discount.
Here’s how it works:
- If a product’s price was €100 for most of the last 30 days, and is now advertised at €80, the retailer must display:
“Lowest price in the last 30 days: €100”. - If the price changed multiple times, the lowest recorded price within that timeframe must be shown – not the original retail price or an average.
This rule applies to all B2C discounts, both online and offline, but not to new products launched for the first time or personalised offers (e.g. loyalty discounts or individual negotiation).
Who is affected by the Omnibus Directive?
The directive applies to all traders selling goods or services to consumers in the EU, including:
- e-commerce websites,
- marketplace sellers,
- mobile shopping apps,
- brick-and-mortar retailers,
- service providers selling to consumers (e.g. gyms, subscriptions, software, events).
Importantly, the directive also applies regardless of the business’s location – if you sell to EU consumers, you must comply with these rules.
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Customer reviews, identity of the trader, and marketplace obligations
Beyond pricing, the Omnibus Directive sets out new obligations around online reviews and commercial transparency.
Key requirements include:
- If a business displays consumer reviews, it must inform users whether and how it verifies the authenticity of those reviews.
- Fake reviews – including paid-for endorsements or testimonials without disclosure – are prohibited under the updated Unfair Commercial Practices Directive.
- Online marketplaces must clearly indicate whether the seller is a trader (professional) or a private individual – and explain who is responsible for contract fulfilment and consumer rights.
These provisions aim to rebuild trust in digital environments, where consumers often rely on star ratings, testimonials, and social proof before purchasing.
How should businesses adapt their systems and processes?
Complying with the Omnibus Directive requires both legal adjustments and technical upgrades. Businesses should:
- Implement automated tracking of price history (especially for SKUs with frequent promotions),
- Update product pages and checkout interfaces to display historical pricing information when needed,
- Add disclosure mechanisms for customer reviews and verification procedures,
- Work with payment service providers that support secure and flexible refund systems, in line with consumer rights to withdraw or cancel orders.
Modern payment providers like Fenige can support compliance by offering:
- Integration with e-commerce platforms for real-time refunds and reversals,
- Detailed transaction reporting and order matching (e.g. by SKU or campaign ID),
- Support for Card-to-Card payouts and multi-channel refund processing,
- Data protection aligned with GDPR and PSD2.
What are the penalties for non-compliance across the EU?
EU member states are empowered to enforce the Omnibus Directive through fines and administrative measures. Depending on local implementation, violations may result in:
- Fines up to 4% of a business’s annual turnover,
- Mandatory public correction notices,
- Temporary suspension of online operations,
- Reputational harm from being listed on national consumer protection watchlists.
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Authorities such as DGCCRF (France), Bundeskartellamt (Germany), or UOKiK (Poland) have already begun monitoring compliance and issuing warnings. Online marketplaces and large retailers are under particularly close scrutiny.
Conclusion
The Omnibus Directive isn’t just another regulatory hurdle – it’s a reflection of changing consumer expectations in a digital-first economy. Shoppers want clear pricing, honest reviews, and transparency about who they’re buying from.
For responsible businesses, this is a chance to lead with integrity and stand out from less scrupulous competitors. By aligning with Omnibus standards – and working with compliant payment and technology providers like Fenige – you can protect your brand, improve conversion rates, and build long-term customer trust.
