The EU Omnibus Directive Explained: Your Complete Guide to E-commerce Compliance on Shopify

The EU Omnibus Directive Explained: Your Complete Guide to E-commerce Compliance on Shopify

The Essential B2B Strategy for Price Transparency and Trust in 2025 and Beyond

Introduction: The New Consumer Protection Paradigm

The implementation of the EU Omnibus Directive (Directive 2019/2161)—also known as the Enforcement and Modernisation Directive—marks the most significant update to European consumer protection laws in a decade. Consumer protection laws are fundamental in regulating online transactions and ensuring fair practices for both businesses and consumers. For e-commerce businesses, especially those operating on platforms like Shopify, this is a pivotal shift in how trust and transparency must be engineered. The EU Omnibus Directive is part of broader EU legislation and union consumer protection rules, which set the framework for these changes and aim to modernize and strengthen consumer rights across the EU. The Omnibus Directive enhances consumer rights stemming from the expansion to digital content, services, and free offerings, placing greater emphasis on informed consumer choice and the enforcement of these rights. Member states are required to implement the directive into their national legislation, ensuring that these new standards are enforced at the national level. Non-compliance carries a severe financial risk, with fines potentially reaching up to 4% of the affected Member State’s annual turnover.

This guide, brought to you by Netkodo, a specialized Shopify implementation partner in B2B IT, dissects the Omnibus Directive’s core requirements, outlines the specific compliance challenges for online stores, and presents expert technological solutions.

 

 

1. Pillar 1: Mandatory Price Transparency – The Lowest Price Rule

The most immediate and impactful change for e-commerce operators is the requirement to make honest price-reduction announcements. The Directive targets the misleading practice of inflating prices before a sale only to announce a deceptive discount. Traders are now obligated to clearly disclose the lowest price from the last 30 days to consumers during any price reduction, ensuring that the actual previous price is transparent. The Directive also introduces transparency requirements for how pricing information is displayed, compelling businesses to provide clear, visible, accurate pricing information to consumers. These rules impose additional obligations on e-commerce businesses to ensure compliance with enhanced consumer protection standards.

What is the new price history requirement?

Any announcement of a price reduction must clearly display the lowest price charged for that product during the 30 days immediately preceding the reduction announcement. This 30-day period serves as the new benchmark for a genuine discount. It defines the scope of the rule, which generally applies to all consumer products except newly marketed (less than 30 days on the market) and perishable goods, and certain promotional offers specified by legislation (discussed below).

• Goal: To provide the consumer with a verifiable basis for the claimed discount, ensuring the reduction is genuine relative to the recent price history. This information must be provided at the pre-contractual stage so that consumers are fully informed before making a purchase.
• The Technical Challenge: The price to be displayed is the lowest recorded price, not just the last regular price. It necessitates automated tracking and reliable IT systems to capture and store the complete pricing history for every SKU and variant in your catalog.

Navigating Exceptions: When Doesn’t the Rule Apply?

While the rule is broad, there are essential practical exceptions, as defined by specific provisions in the directive:

1. New Products: Goods on the market for less than 30 days must show the lowest price applied since their launch.
2. General Loyalty Programs: Price reductions that are not publicly advertised but are granted personally to a specific customer or group (e.g., standard loyalty points or individual coupon codes) are often exempt. Note that certain provisions regarding these exemptions may be subject to interpretation or adaptation under national law or national laws in different member states.
3. Products with Short Shelf-Life: Exemptions apply to rapidly perishable goods, in which case the merchant must provide the price from before the first application of the reduction. Some provisions related to these exemptions may also vary depending on national law.

2. Pillar 2: Building Trust – Verification of Consumer Reviews

The Directive addresses the erosion of consumer trust by cracking down on the manipulation of social proof. The following are considered unfair commercial practices under the Omnibus Directive: maintaining customer trust now requires verifiable review authenticity to combat the proliferation of fake reviews. Traders are now obligated to ensure that published reviews are genuine and to disclose how they ensure that the reviews originate from actual consumers who have purchased or used the product or service. These requirements also apply to reviews of digital content and digital services.

The Obligation to Verify Reviews - What Does Reasonable and Proportionate Mean?

If your store provides access to customer reviews, you must take reasonable and proportionate steps to ensure they originate from consumers who actually purchased or used the product.

• Key Requirement: The seller must clearly inform consumers whether and how the reviews displayed have been verified  (linked to a verified purchase order). In the context of an online marketplace, the party offering the product or service—whether a trader or not—must be clearly identified based on the third party's declaration to the marketplace provider. Transparency requirements also apply, meaning you must disclose the methods used to verify reviews.
• Prohibited Practices: It is explicitly an unfair commercial practice to:
  • Falsely claim that reviews have been verified.
  • Submit or commission fake reviews or endorsements.
  • Manipulate reviews (selectively publishing positive reviews while suppressing negative ones).

Shopify Store Implementation: Required Disclosure

To ensure compliance, Shopify merchants must update their review mechanisms and transparently detail their policy. Merchants are required to disclose all relevant details of their review verification process, including how reviews are collected, verified, and linked to actual orders. It requires an IT solution that links review collection to order data and a compliance policy that is clearly visible to the customer. These measures are intended to achieve better enforcement of consumer protection standards.

3. Pillar 3: Transparency in Personalized Pricing and Marketplaces

The Directive ensures that the use of advanced AI-driven personalization in e-commerce remains transparent, thereby addressing potential algorithmic discrimination. Its rules apply to both physical goods and digital services, ensuring that consumer protection extends to a wide range of online transactions.

These requirements apply to online stores, platforms that facilitate third-party sales, and digital service providers, ensuring that both physical goods and digital content are covered. The Directive introduces transparency requirements for personalized pricing and seller identity, obliging traders to disclose when prices are tailored based on consumer profiling clearly and to identify whether the seller is a trader or not.

In the context of online marketplaces, consumers must be provided with additional information about the party offering the product or service. This includes a clear disclosure of whether the third party is a trader, as determined by the declaration made to the marketplace provider.

Disclosing Algorithm-Driven Price Adjustments

Traders must clearly inform consumers when the price being offered has been personalized based on automated decision-making and profiling of consumer behavior (e.g., location, browsing history, purchase power assessment). The process by which these personalized prices are determined typically involves collecting and analyzing consumer data using AI algorithms, which adjust prices in real-time. The principle of transparency underpins these disclosure requirements, ensuring consumers are aware of how their data influences pricing. Failure to comply with these obligations may result in proportionate penalties as outlined in the directive.

• B2B/Tech Insight: This requires sophisticated IT systems and AI engines used for dynamic pricing to have a compliant disclosure mechanism that is visible before the purchase is completed. This is a technical challenge that demands deep system integration expertise.

New Rules for Online Marketplaces

Platforms connecting third-party sellers and consumers have specific new duties that require structural data updates:

1. Seller Status: Clearly inform the consumer whether the third-party seller is a trader (professional) or a private individual.
2. Ranking Transparency: Disclose the primary parameters that determine the ranking of products in search results, as well as whether payment by a seller affects this ranking.
3. Reviews verification: The relevant provisions in the Omnibus Directive also require online marketplaces to ensure that published reviews are genuine and to disclose the origin of these reviews, thereby providing transparency about the verification process for consumer feedback.

4. The Stakes: Non-Compliance and UOKiK Fines

The threat of financial and reputational damage from non-compliance is substantial and is the core driver for B2B IT investment in compliant solutions. The Omnibus Directive aims to sanction intra-union infringements and address them through effective enforcement measures. It requires proportionate penalties to deter non-compliance and mandates that national authorities coordinate enforcement. The directive also ensures that individual remedies are available for consumers affected by violations. To close remaining gaps in enforcement, Member States may use other means, such as administrative or judicial actions, in addition to traditional penalties.

 

 

Crucial Point: Enforcement bodies, such as Poland’s Office of Competition and Consumer Protection (UOKiK), are actively monitoring compliance, as evidenced by recent high-profile cases. Waiting for a legal challenge is a risk few scaling Shopify merchants can afford.

5. Netkodo Expert Solution: Achieving Shopify Omnibus Compliance

Compliance with the 30-day price history rule is a specialized technical challenge. This solution is designed for companies seeking to effectively comply with the directive, supporting their corporate sustainability and due diligence efforts. We recognized that manual tracking and clunky workarounds expose businesses to unnecessary risk.

Introducing the Omnibus by Netkodo Plugin

As a specialized Shopify implementation partner, we engineered a high-performance, compliance-focused application: the Omnibus by Netkodo plugin.

• Value proposition: The plugin automatically logs and stores the required 30-day price history data and renders the compliant lowest price display widget directly on the product page, with no coding required. It removes the need for manual tracking, eliminating human error. It’s designed to avoid the errors associated with manual data entry and non-product discounts (e.g., loyalty discounts). The compliance features are based on the requirements set out in the relevant council directive as published in the official journal of the EU, ensuring your business meets the latest legal standards.
• Engineered for B2B: Our solution is built for reliability, supporting complex catalogs, multi-currency needs, and dynamic pricing structures without performance degradation.
• The competitive advantage (strategic pricing): Unlike overly complex or premium alternatives, the Omnibus by Netkodo plugin offers a best-in-class, attractively priced solution. We provide B2B-grade compliance efficiency without the prohibitive subscription cost, ensuring a superior cost-to-compliance value for your business.

More about the Omnibus by Netkodo in the case study: Complex Legal Mandate Turned into a Simple, Automated Solution

Netkodo B2B E-commerce Expertise: Beyond the App

The plugin is a testament to our commitment to forward-thinking IT solutions. For clients needing comprehensive platform support, our services extend further:

• Compliance audits: Full technical and legal audits of your Shopify Plus or standard platform setup.
• Custom legal integration: Tailored development to integrate specific national legal requirements and data disclosure mechanisms, ensuring solutions are adapted to requirements at the national level and in accordance with national laws.
• AI & pricing consulting: Strategic consulting on implementing AI-driven pricing while maintaining Omnibus disclosure obligations.

We provide IT expertise to ensure complex legal requirements are integrated into your operational backbone so that you can focus on growth. Our team works closely with national authorities to ensure compliance and supports clients across the EU.

Conclusion: The Path Forward – Trust Through Technology

The broader impact of the Omnibus Directive and related EU legislative processes extends far beyond compliance. Protecting fundamental rights and ensuring a sustainable future for the next generations depend on reliable consumer protection and the inclusion of affected communities in every legislative process. 

The Omnibus Directive is a powerful lever for strengthening consumer trust, but it requires proactive IT investment. For Shopify merchants, the time for automated, verified compliance is now.

Netkodo is your strategic partner in transforming legal risk into a competitive advantage. By demonstrating verifiable price transparency and genuine reviews, you don’t just avoid fines - you build a loyal customer base and secure your platform’s long-term sustainability.

Achieve instant and affordable compliance: Install the Omnibus by Netkodo Shopify App today and lock in automated price history tracking.

For enterprise-level compliance audits, custom platform integrations, or complex legal-tech consulting, contact Netkodo B2B IT specialists.