The EU Omnibus Directive: What the 30-Day Lowest-Price Rule Means for Influencer Discount Codes

Short answer: the rule applies no matter who announces the discount

Since 28 May 2022, Article 6a of the EU Price Indication Directive (98/6/EC), inserted by the Omnibus Directive (EU) 2019/2161, has required that any announcement of a price reduction state the prior price — defined as the lowest price the trader has used for the product in a period of at least 30 days before the reduction. Denmark implements the rule through its own price-marking guidance and Forbrugerombudsmanden's own guidelines for price marketing. The point that matters for an influencer campaign: the rule targets any announcement of a price reduction — not only a brand's own campaign pages. A discount code an influencer posts in a Reel or a Story is still an announcement of the brand's price, just through a different messenger.

What Article 6a actually says

The directive's own text is short and specific: any announcement of a price reduction must indicate the prior price applied by the trader for a determined period before the reduction — and the prior price is defined as the lowest price the trader has applied during a period of not less than 30 days before the reduction. Member States may set different rules for goods liable to deteriorate or expire quickly. The provision was inserted into the original 1998 Price Indication Directive by the Omnibus Directive, and it has applied across the EU since 28 May 2022 — confirmed in the European Commission's own guidance on the article (Commission Notice 2021/C 526/02).

Denmark's implementation: normalpris and Forbrugerombudsmanden's guidance

Forbrugerombudsmanden's own price-marketing guidelines put the rule directly, in Danish: "Som normalpris anses den laveste pris, som den erhvervsdrivende har anvendt for varen i en periode på mindst 30 dage forud for prisnedsættelsen" — the normal price is considered the lowest price the trader has used for the product in a period of at least 30 days before the reduction. Per the same guidance, the reduction itself should generally run no longer than around 10 days before it stops functioning as a genuine "reduction" and effectively becomes the new normal price. A shorter, 14-day period applies to goods that deteriorate or become obsolete quickly — Denmark's own use of the directive's allowance for different rules on that category.

Does this apply to an ordinary "CODE20 for 20% off" influencer post?

The question that matters is whether the post is an announcement of a price reduction — that is, whether it directly or indirectly compares an offer price to a normal price. A code that takes a fixed amount or percentage off a brand's ordinary price is exactly that. Forbrugerombudsmanden's guidance addresses discount coupons generally and doesn't carve a discount code out of the ordinary rules just because it's distributed by an influencer rather than the brand directly. A shared, publicly available code also isn't a "personal," individually negotiated discount in the sense the guidance means — it's a general price reduction that anyone who sees the post can use, and it has to meet the same requirements as any other sales campaign.

The legal responsibility for the normal price being correct sits with the trader — the brand that sets the price — not with the influencer personally. That doesn't change the fact that a campaign launched through an influencer's channel with an inflated or incorrect "normal price" is just as exposed to Forbrugerombudsmanden's enforcement as if the brand had posted it on its own webshop.

The trap in multi-phase influencer campaigns: the continuous campaign

An influencer campaign that activates several creators over several days or weeks with increasing discount depth runs directly into a specific point in Forbrugerombudsmanden's guidance: "I tilfælde, hvor prisnedsættelsen i en sammenhængende markedsføringskampagne øges progressivt, anses normalprisen som den pris, der gjaldt før den første prisnedsættelse" — where the discount in a continuous marketing campaign increases progressively, the normal price is considered the price that applied before the first reduction. In other words: once the campaign is underway, a brand can't reset the "normal price" to yesterday's already-discounted price to make the next wave's discount look correct on paper — the reference stays the price the product had before the campaign started at all. That has a direct, practical consequence for how a multi-phase campaign with different creators at different discount tiers should be briefed — see the worked example below.

Real enforcement — this isn't theoretical

Forbrugerombudsmanden actively enforces these rules, though none of the publicly known cases below is specifically an influencer campaign — they show the enforcement environment a brand-driven influencer discount-code campaign operates inside:

• ILVA (4 December 2025): Forbrugerombudsmanden filed a police report against furniture chain ILVA for 29 violations of the price-marking rules. Several products were on sale for so much of the time — a dining chair for 72 of 112 days, a sofa for 42 of 84 days — that, per Forbrugerombudsmanden, the stated "normal price" became more theoretical than real, and several offers failed the requirement that the normal price be the lowest price in the preceding 30 days.
• Camilla Krøyer Jewellery (21 November 2024): Forbrugerombudsmanden issued a reprimand after the jewellery brand advertised a time-limited discount code on Facebook that was actually valid for considerably longer than stated — a case about the code's stated duration, not the 30-day rule itself, but in the same enforcement track: a discount that wasn't what the post promised.
• Wolt Denmark (18 March 2026): Forbrugerombudsmanden filed a police report against Wolt over a push notification sent to roughly 45,000 consumers advertising "25% off," where the discount was actually capped at 30 kr — which for many orders meant a real discount under 16%, not the advertised 25%.

What the cases share: Forbrugerombudsmanden pursues the real discount a consumer experiences, not just the number stated in the post — and it acts against businesses across channels, not only classic webshop sale pages.

What this means for the fine

It's a common but imprecise assumption that any violation can be fined up to 4% of a company's annual turnover. Markedsføringsloven § 37, subsections 1–3 set fines for an ordinary Danish violation based on "the severity of the infringement and the trader's turnover" — with no fixed percentage ceiling in the statute itself. It's § 37, subsections 8–9, that carry the 4% ceiling, and that provision applies specifically when the infringement harms consumer interests in at least two other EU countries besides Denmark — Denmark's implementation of Article 13(3) of the EU's Unfair Commercial Practices Directive, inserted by the Omnibus Directive. An ordinary Danish influencer discount-code campaign that only reaches Danish consumers is therefore assessed under the severity-and-turnover test in subsections 1–3 — not the cross-border 4% ceiling.

Worked example: the continuous campaign's normal price (hypothetical, illustrative only)

The figures below are invented to illustrate how the 30-day rule and the progressive-discount rule interact — this is not a Make Influence customer case, and none of the figures are benchmarks.

A brand sells a product at DKK 799, a price that has held for more than 30 days. The brand runs a continuous two-week influencer campaign with two creators, activated back to back, without the price returning to DKK 799 between the two waves:

• Week 1 — Creator A's code, 15% off: DKK 799 × 0.85 = DKK 679.15. Correct: this is the campaign's first reduction, and the reference is the genuine normal price of DKK 799.
• Week 2 — Creator B's code, 30% off: The correct calculation still uses DKK 799 as the reference, because the campaign is continuous: DKK 799 × 0.70 = DKK 559.30, marketed as "30% off the normal price of DKK 799."
• The shortcut some brands try: calculating week 2's 30% off week 1's already-discounted price instead — DKK 679.15 × 0.70 = DKK 475.41, and calling that "30% off." Measured against the genuine, fixed reference price of DKK 799, DKK 475.41 is actually a discount of (799 − 475.41) ÷ 799 = 40.5% — not the advertised 30%. The price the customer sees at checkout can easily be correct and a genuinely good deal; the problem is that the "30%" signage no longer reflects the true saving, because the reference price was reset mid-campaign. That's exactly the situation the guidance's progressive-discount rule is written to prevent.

Decision framework: does the normal price need checking before a creator posts the code?

• IF the post or the code implies a discount off a "normal," "before" or "recommended" price → the normal price needs to be documentable as the lowest the brand has used in the preceding 30 days (14 days for goods that deteriorate quickly).
• IF the code only gives a discount with no comparison to a prior price at all (e.g. "use CODE20 for 20% off" with no "before/now" wording) → it's still worth holding to the same documentation standard in practice, even though Article 6a specifically addresses announced price reductions — Forbrugerombudsmanden's general prohibition on misleading marketing reaches wider than the 30-day rule alone.
• IF the campaign runs several creators back to back with increasing discount depth → hold on to the original normal price from before the campaign's first reduction throughout the whole run, no matter how many waves follow.
• IF there's genuine doubt whether the price actually held for 30 days → delay the campaign, or use discount wording that doesn't compare against a "normal price" at all.

Make Influence's recommendation

We recommend writing the normal price a campaign has to calculate from directly into the brief as a fixed figure — alongside the campaign's start and end dates — rather than leaving each creator or marketer to work it out as the campaign runs. For multi-phase campaigns with several creators over time, we recommend naming one person who owns the campaign's full pricing history and can confirm that each wave's "discount" figure is still calculated from the original normal price — not from last week's already-discounted price. That's a small administrative task next to the consequence of a police report like the ILVA case.

FAQ

Is the influencer personally legally liable if the normal price is wrong?

No, not as a starting point. Responsibility for correct price marketing sits with the trader — the brand that sets and announces the price — regardless of whether the announcement happens through the brand's own channels or through an influencer's post.

Does the 30-day rule apply if the discount code only works for one influencer's followers?

Yes. The rule doesn't distinguish based on how widely a code is distributed — what matters is whether the announcement compares an offer price to a normal price, not how many people can see the post.

Can we reset the normal price if we pause the campaign between two waves?

It depends on whether the pause genuinely breaks the campaign's continuity, and whether the price actually returns to and holds at the original price for at least 30 days again. A short pause with no real return to the normal price isn't enough to reset the reference — seek specific advice if this applies to an actual campaign.

What if the brand has never actually sold the product at DKK 799 for 30 consecutive days — only ever on sale since launch?

Then there's effectively no valid "normal price" to compare against yet, and an "X% off" claim risks being misleading because it implies a price that has never existed as a genuine, held price.

Is this the same as the ad-disclosure rules for influencer posts?

No, these are two separate rule sets that can both apply to the same post. This article covers whether the discount/price claim itself is accurate and documented. See influencer marketing disclosure rules in Denmark and the EU for the separate duty to mark the post as an ad.

How does this relate to whether a discount code cannibalises the brand's margin?

They're two different questions that often come up in the same campaign. This article covers whether the price claim is lawful and correctly documented. See do influencer discount codes cannibalise your margin for how the discount's depth affects your contribution margin, independent of whether the price marketing itself is compliant.

Are a discount code and a tracking link subject to the same price rules?

No — a plain tracking link with no attached discount doesn't compare an offer price to a normal price, so it doesn't trigger Article 6a's requirements at all. See discount codes vs tracking links for the difference between the two tracking methods.

Does this apply to a Danish influencer's affiliate-network codes too, not just curated brand deals?

Yes — the rule attaches to whatever price the trader is advertising, regardless of whether the code reached the influencer through a curated brand relationship or an open affiliate network. See affiliate influencer marketing in Denmark for how the Danish affiliate market itself works.

Is this related to the EU's BNPL/consumer credit rules covered elsewhere in the Academy?

No — they're separate EU consumer-protection rules that can both touch a checkout-adjacent influencer post. This article covers price-reduction claims; a separate rule under Markedsføringsloven § 18 applies specifically to numerical claims about the cost of credit, such as "interest-free." See BNPL in influencer marketing: what the EU's consumer credit rules mean from 2026 for that separate rule.

Is a competitor comparison claim covered by this same rule?

No — they're related but legally distinct. This article covers whether a "normal price" claim is genuine. A separate rule, § 21 of markedsføringsloven, covers whether a comparison with a named competitor is fair and documented. See when does an influencer's "X vs Y" comparison count as comparative advertising under Danish law? for that rule.

Does the 30-day price rule have anything to do with the customer's right to return the product?

No — they're two separate questions. This article covers whether the discount's price claim is accurate and documented. See does Denmark's 14-day right of withdrawal change for influencer discount code sales for whether and how the customer can withdraw from a discount-code purchase.