Discount advertising in the UAE is a regulated consumer-facing claim, not simply a marketing design choice. A promotion may create legal risk when the reference price is artificial, the “saving” is unavailable in practice, material conditions are hidden, the advertised stock is not reasonably available, or the provider adds a price or payment condition after the consumer commits.

Federal Law No. (15) of 2020 on Consumer Protection, as amended, and Cabinet Resolution No. (66) of 2023, its Executive Regulation, provide the principal federal framework. The rules apply to goods and services in the UAE, including e-commerce where the supplier is registered in the UAE. Local economic departments and other competent authorities may add licensing or campaign procedures.

What counts as a discount or promotion?

The Consumer Protection Law treats discounts as offering goods at reduced prices or providing services at lower prices during a specified period. Promotion includes marketing through prize draws, gifts, special offers, or other advertising methods. A campaign can therefore be regulated even when it does not use the word “sale”.

Examples include “buy one get one”, a coupon code, flash sale, clearance event, cashback, bundle price, loyalty reward, free gift, prize draw, influencer code, and a “launch price” that is compared with a future price. The legal analysis turns on what the consumer is being promised and whether the claim is accurate, transparent, licensed, and capable of proof.

The basic rule: prices and savings must not mislead

Federal Law No. (15) of 2020 requires the provider to display the price clearly and provides that advertising the prices of goods and services must not be misleading. The provider must also issue a detailed Arabic invoice showing the trade name, address, commodity or service, price, quantity or service details, and other required information.

A “was/now” claim should be supported by reliable price records. The reference price should reflect a genuine price at which the same product, specification, and quantity was offered for a meaningful period or under a defensible commercial policy. A provider should not raise a price shortly before a sale simply to advertise a larger percentage saving.

The same discipline applies to “up to 70% off”, “lowest price”, “best deal”, “clearance”, “limited-time offer”, “free”, “guaranteed saving”, and “price match” statements. The claim should be true for the goods shown, or the qualifying limitation should be immediate, prominent, and understandable.

What makes a promotion misleading?

Cabinet Resolution No. (66) of 2023 treats a description, advertisement, or offer as deceptive when it contains a misleading statement that may directly or indirectly create an unreal or misleading impression. The listed areas include the product’s characteristics, origin, quantity, contract terms, after-sales service, warranty, price, payment method, awards, certificates, trademarks, and expected results.

For discount campaigns, common risk patterns include:

  • showing a reference price that was not genuinely available to consumers;
  • advertising a percentage reduction that applies only to a small or unavailable part of the range;
  • hiding mandatory delivery, service, payment, subscription, or minimum-spend conditions;
  • using “free” or “no cost” language while recovering the price through another compulsory charge;
  • advertising a countdown or scarcity claim that automatically resets or is not supported by stock data;
  • describing a product as clearance, new, original, or authorised without evidence;
  • advertising a prize, gift, coupon, or cashback benefit without clear eligibility and fulfilment terms; and
  • changing the price, quantity, warranty, or return condition after the consumer has accepted the offer.

Promotion and discount licences

Article 18 of the Consumer Protection Law prohibits promoting goods or services, making general price discounts, or advertising them without a prior licence from the competent authority. Article 31 of Cabinet Resolution No. (66) of 2023 states that a provider making or announcing discounts by any means must obtain a prior licence, and a provider promoting goods or services by any means must also obtain a prior licence, following the procedures of the competent authority.

The required process may depend on the emirate, activity, sales channel, campaign structure, sector, and whether the campaign includes a prize draw or other regulated feature. A national campaign should not assume that one approval automatically covers every emirate, store, website, social-media account, marketplace, or participating supplier.

Keep the licence, application, approved campaign artwork, product list, dates, participating outlets, terms, stock plan, influencer instructions, and closing report together. Do not launch the social-media post, paid advertisement, email, landing page, or in-store material before the responsible compliance owner confirms the applicable approval.

Reference prices and the evidence file

Before publishing a discount, build a reference-price file for each product group or service. It should contain:

  • the ordinary price, date, channel, currency, tax treatment, and product specification;
  • the period during which the reference price was offered and the number of units or bookings actually available;
  • the sale price, percentage calculation, promotional code, minimum spend, quantity limit, and excluded items;
  • inventory, order, cancellation, refund, and price-change records;
  • approved artwork, web pages, checkout screens, terms, and translations; and
  • the calculation and evidence supporting every “saving”, “lowest price”, or comparative claim.

For services, compare like with like. A reference price for a weekday appointment, basic package, or limited service cannot be presented as the ordinary price of a premium or all-inclusive package without an explanation that prevents a misleading impression.

Short-notice discounts and the consumer’s price-difference remedy

Article 31 of the Executive Regulation requires the provider to notify the consumer of a discount where the specified start date of the discount is within one week from the consumer’s purchase. If the provider fails to give that notification, the consumer has a right to recover the price difference within 30 days from the purchase date.

This is a specific statutory remedy, not a general right to claim every later price reduction. The consumer should preserve the receipt, the original advertised price, the later discount notice, the product identity, and the date of purchase. The provider should have a process to identify affected transactions, calculate the difference, communicate the remedy, and document payment or rejection.

Online and marketplace promotions

E-commerce promotions must be consistent across the product page, search result, banner, coupon, checkout, invoice, payment gateway, delivery screen, and customer-support response. If the discount requires a code, account, location, payment method, minimum spend, subscription, or quantity, the condition should appear before the consumer commits.

Marketplaces should allocate responsibility between the platform, seller, advertiser, payment provider, and logistics provider. A platform that chooses the headline claim, controls the checkout, collects payment, or promises the refund may face direct questions about the promotion even if the seller supplied the product data.

Keep a versioned record of the campaign as shown to each consumer. Do not rely on a current webpage to prove what a consumer saw after the campaign was edited or removed.

Price displays, invoices, and payment conditions

Displayed prices should be clear and readable. The consumer should be able to see the sale price, reference price where used, VAT or other compulsory charge, delivery or service fee, payment-condition surcharge, and total payable amount before ordering.

The Executive Regulation also addresses price displays and discount cards. If a provider accepts discount cards, the discount value and acceptance should be clearly stated. A provider should not add an amount to the price because the consumer uses a credit card where the applicable rules prohibit that practice.

Invoices and receipts should reflect the actual transaction. A discounted invoice that omits the original price, coupon, delivery fee, or compulsory condition can make it harder to resolve a complaint and harder to prove that the campaign was honestly administered.

Consumer remedies and corrective action

A misleading discount may support a consumer complaint, recovery of a price difference where Article 31 applies, cancellation or refund under the facts and applicable consumer rules, compensation for damage, and regulatory action. If the product or service is also defective, warranty and after-sales remedies apply independently.

The provider should pause a disputed claim, preserve the campaign evidence, identify affected consumers, correct the advertisement, remove misleading material, honour valid claims, refund or compensate where required, and report internally on root cause. A silent deletion without a record can appear evasive and prevents accurate remediation.

Administrative and commercial-control exposure

The Consumer Protection Executive Regulation includes an administrative-penalty annex. Its published examples include AED 100,000 for misleading price announcements, AED 100,000 for failing to issue an Arabic invoice, and other penalties for consumer-protection failures. The applicable entry, authority, and procedure must be checked against the current Arabic text and the facts.

Misleading discount conduct may also overlap with anti-commercial-fraud, licensing, competition, e-commerce, tax, product-safety, or local commercial-control rules. A campaign involving false origin, counterfeit goods, fake prizes, manipulated reviews, or concealed mandatory charges can create exposure beyond a price-advertising dispute.

Practical campaign checklist

  1. Define the exact product, service, channel, dates, territory, audience, and participating provider.
  2. Confirm the required discount, promotion, prize, advertising, and local authority licences before launch.
  3. Validate the reference price, saving calculation, stock availability, and comparison period.
  4. Disclose minimum spend, quantity limits, payment method, delivery charge, exclusions, expiry, and refund terms prominently.
  5. Make every landing page, banner, influencer post, coupon, checkout, invoice, and Arabic translation consistent.
  6. Preserve an evidence file containing approved artwork, price history, inventory, licence, terms, and consumer-facing versions.
  7. Monitor price changes, stock-outs, automatic countdowns, rejected coupons, and complaints during the campaign.
  8. Identify purchases made shortly before a discount and assess the 30-day price-difference remedy.
  9. Correct or suspend claims that cannot be substantiated and document consumer remediation.
  10. Review the campaign against the current Arabic law, Executive Regulation, competent-authority procedures, and sector-specific rules.

How HZ Legal can help

Hossam Zakaria Legal Consultancy can assist with discount and promotion licensing, reference-price evidence, Arabic campaign terms, influencer and marketplace advertising review, consumer complaints, price-difference claims, regulatory responses, and commercial-control investigations. Visit HZ Legal to discuss your promotion.

Official sources and verification

Editorial verification before publication: Confirm the current Arabic text, amendments, emirate-level discount and promotion licensing procedures, campaign-specific approvals, product-sector requirements, and the precise remedy or penalty applicable to the facts. Reference-price analysis should be supported by contemporaneous records, not only by the creative brief.

Prepared on 11 October 2026. General legal information, not advice on a particular promotion, advertisement, or consumer claim.