A disclosure policy for UK ecommerce stores: ads, prices and reviews on Shopify, BigCommerce, Wix, Squarespace and WooCommerce

What to take away

Classify each communication before drafting

Give every item a type: editorial text, merchant product claim, paid placement, affiliate link, creator endorsement, customer review, price statement, optional extra, privacy notice or tracking control. Record the legal entities, relationship, audience, channel, product, start date and owner. If two categories apply, keep both gates separate.

The CMA's unfair commercial practices guidance (CMA207) treats a failure to identify commercial intent as a misleading omission. A consumer lawyer should apply that rule to the exact presentation, not to a supplier label, and the UK rule map shows where each rule sits in a store journey. The predecessor framework was the Consumer Protection from Unfair Trading Regulations 2008 (SI 2008/1277); the current unfair-commercial-practices regime is in the Digital Markets, Competition and Consumers Act 2024.

Seller identity, checkout data and exit terms belong in the store itself. Record the registered company name and Companies House number, any VAT number, a returns address and the notice the platform requires before the account closes. The market entry checklist is a place to hold those fields against each trading name.

Where each store builder puts the wording

Treat store content and app-owned widgets as separate surfaces: a hosted checkout may constrain what you can change, while WooCommerce theme code is merchant-managed. Record the field or template that controls each disclosure, then test it after theme or app changes.

Check four things in any platform you shortlist:

How the five platforms compare on disclosure control

The platforms differ in how much of the page you control. On the hosted builders (Shopify, BigCommerce, Wix and Squarespace), the platform owns the checkout and app widgets, so you set wording through product fields, page content and app settings, and you cannot always move an app-owned label. WooCommerce gives full control of templates and checkout code, but you maintain every change and test it after updates.

For disclosure, that means choosing by capability: can you place a sponsored label above the first link, show the total price before payment, start optional extras unticked and attach a verified or incentivised label to each review? Test those four on a demo store in each platform you shortlist, rather than relying on the feature list.

The policy in one page

Adopt these rules as the store's disclosure policy, filling each owner and date.

Specify placement for ads and prices

The CAP Code section 2 rules on recognition require obvious recognition and clear treatment of advertorials. Define what a consumer sees before any interaction: mobile crops, search cards, video frames, emails and landing pages. Record approved wording, contrast, position and test evidence.

Price information needs a placement rule. The CMA's Price transparency: advice for businesses guidance covers mandatory fees, taxes, drip pricing and partitioned amounts. Link each displayed amount to a dated price source. Show unavoidable charges before the customer commits. Optional extras need an active choice, per CMA consent guidance. A note after payment cannot repair a default.

Example: sponsored placement and price block wording

Use this approved wording for a sponsored placement:

Sponsored: paid partnership with [Brand]. We earn a commission if you buy through this link.

Place that label directly above the headline or first image, before any link, and keep it visible without scrolling on a 360px wide mobile screen.

Use this approved wording for a price block:

Total price: £149.99 including VAT and delivery. No further mandatory charges at checkout.

Place the total beside the product title and again in the basket summary before payment. Show any optional extra as an unticked box. Illustrative figure: £149.99.

Example: review disclosure wording

Use this approved wording for a verified customer review:

Verified purchase: this review comes from a customer who bought the item from our store. We did not pay for it.

Use this approved wording for an incentivised or paid review:

Incentivised review: we supplied this product free of charge. The reviewer is not an employee and the review was not edited by us.

Place the label with the review itself, above or beside the star rating in the review card, before publication and before any syndication that carries the text elsewhere. A footer or a separate policy page is not enough, and the label must stay visible without scrolling on a 360px wide mobile screen.

Review collection tools such as Trustpilot, Feefo, Reviews.io and Judge.me can hold the purchase or order record with the review and export it as evidence. A review that arrives without a purchase record should be recorded as unverified.

Keep a claim register with filled rows

CAP's substantiation advice says documentary support for objective claims should be held before publication. The record also feeds the England merchant guide for 2027, which covers platform features that change the disclosure workload.

For reviews, store whether the contributor bought or used the item, any incentive, commercial connection, moderation and edit history. The CMA's Online reviews: guidance for businesses calls for genuine, relevant and lawful reviews plus clear policies and reasonable checks. Do not publish an invented quotation or present an incentivised review as independent.

Separate privacy communication from consent

List each cookie, pixel, script or similar technology by party and purpose. The ICO's storage and access technologies guidance treats clear information, exceptions, consent and controls as separate questions, so check its current version. A privacy link does not itself create valid consent. Record what loads before selection, after refusal and after withdrawal. For UK stores, map tracking to the Privacy and Electronic Communications Regulations 2003 (PECR) and UK GDPR as well as the ICO guidance.

If you use an agency or a platform app, the vendor due diligence paper trail helps fix the contract terms that matter to disclosure: which party is the controller and which is the processor for order and review data, what the app may do with that data, how long it keeps it, what it hands back on termination and how much notice either side must give.

Version, correct and withdraw

Set a version number, approval date and expiry for every disclosure. When something goes wrong, follow these steps:

The correction procedure should align with the contract terms that cover data roles and exit, because withdrawal duties depend on who can pull the placement. The consumer law lead signs corrections.

The privacy lead signs tracking changes. Across the UK, the CMA can investigate misleading omissions and enforce consumer protection law, while the ASA can ban non-compliant ads and publish rulings.

Common questions

What must a sponsored placement say in England?

It must be recognisable as marketing before the click or view. Use a label such as "Sponsored" or "Paid partnership" next to the headline, not in a footer. The CAP Code requires obvious recognition.

What price details must appear in the first view?

Show the total price including VAT and unavoidable fees. The CMA's Price transparency: advice for businesses guidance covers mandatory fees and drip pricing. Optional extras need an active choice.

How long should a disclosure record be kept?

Keep the record for the life of the claim plus your limitation period, and add an expiry date. Reviews need contributor purchase history and incentive status. Version each change with a date and owner.

Where must a review label sit?

On the review itself, above or beside the star rating in the review card, before the review is published and before it is syndicated anywhere else. A footer or a general policy page is not enough, and an incentivised review needs its own label rather than a line in the site policy.