Can a small shop risk these sale tactics?

On the public record, the competition regulator has never gone after a small shop. We looked, and couldn't find a single case. Before you dust off the countdown clock, though, that isn't the same as being safe. The rules apply to any business selling to consumers, the CMA isn't the only body that enforces them, and most of the practices in this series are crimes as well as civil breaches, with fines of up to £300,000, or 10% of turnover if that's higher, as the CMA's own guidance sets out.

Our interest, stated first. We sell marketing, including the 90-day plan a November sale would sit inside, so warning you off risky tactics costs us nothing. We've tried to say exactly what the record shows, and exactly what it doesn't.

This is the last part of our series on sale prices and urgency, checked. Like the rest, it reports what the evidence and the regulators say, with a link to each source, and it isn't legal advice.

What the record shows

On 29 September 2026 we went through every case in the CMA's case finder, filtered to the type "consumer enforcement" and updated since 1 January 2022. There were 41, and not one was against a small independent shop. The nearest was its 2026 heating oil review, in which suppliers the CMA didn't name agreed to pay compensation. When it launched its pricing drive, the CMA said it would "focus early enforcement action on the most egregious practices which are harmful to consumers". Notice that it says the worst practices, not the biggest companies.

Trading Standards cases aren't collected anywhere we could search, so we can't tell you how likely enforcement is for a business your size. And "it probably won't be me" is a poor thing to build a sale on.

Why being small doesn't protect you

• The rules don't care how big you are. The CMA says its price rules apply "to anyone who sells, advertises, markets or otherwise promotes a product to customers". That's everyone, down to the smallest shop.
• The CMA isn't the only enforcer. Its enforcement guidance lists Trading Standards among the enforcers of consumer law, alongside the Financial Conduct Authority, Ofcom and the Office of Rail and Road, and notes that "Not every enforcer is authorised for every infringement".
• Most of these practices are crimes. The CMA's guidance says most banned practices are criminal offences, and "strict liability offences" at that, which means "There is no need to prove the intent of the trader". So not meaning to mislead anyone doesn't get you off on its own. A few practices do build a purpose into their wording, such as a false time limit used "in order to elicit an immediate decision". The Act gives a trader two defences, due diligence and innocent publication, and it's for the trader to prove either one.
• The fine has a fixed ceiling. The CMA or a court can fine a business up to £300,000, or 10% of its turnover if that's higher, as both its unfair practices guidance and its enforcement guidance set out. If your turnover is under £3 million, your ceiling is £300,000.

What to do instead

Use the series as a checklist: honest "was" prices, real countdowns, fees inside the advertised price, an "up to" figure your range can support, and stock messages that are true. None of that stops you running a good sale. It just keeps the sale honest, which is cheaper than the alternative. If you're planning a November push, our 90-day marketing plan is where I'd start.