Black Friday offers on your hotel website: 'was/now' prices, 'only 2 rooms left' and countdown timers, what you can say (2026)

Updated: 9 November 2026

Black Friday is on 27 November 2026. Many hotels will launch offers on their website, with crossed-out prices, low-availability alerts and countdown timers. You can use all of these, but only if they are true and you can prove it. These are the rules we checked in official sources (links at the end), and what we could not confirm. This is not legal advice: check unclear cases with a lawyer.

The golden rule: only what you can prove

The EU Unfair Commercial Practices Directive (2005/29/EC) protects consumers from false information about goods and also about services, such as a hotel night. Lying about the price or about a price advantage is misleading (art. 6(1)(d)). Before publishing an offer, ask yourself: can I prove this is true?

'Was/now' prices: which prior price to use

Directive 98/6/EC says that when you announce a price reduction, the prior price is the lowest you applied in at least the previous 30 days. The official EUR-Lex summary refers to 'products' and lets countries exempt products supplied in the course of providing a service.
Whether this 30-day rule also binds hotels we could not confirm: the Commission's December 2021 guidance could not be opened.
Even so, an invented or inflated 'was' price is misleading under the unfair practices directive, which does cover services. The safe approach: use as 'was' the lowest price you charged for the same room and rate in the previous 30 days, and keep a screenshot or a report from your booking engine.
Compare like with like: same room, same dates or season, same conditions (breakfast, cancellation). An August price is not the 'was' price of a November night.

Country by country

Spain: the Unfair Competition Act treats as misleading lying about the price or a price advantage (art. 5.1.e) and falsely claiming that a good or service will only be available for a very short time (art. 23.4). Law 7/1996 (art. 20) requires showing, next to the reduced price, the prior price, the lowest of the previous 30 days; it refers to 'articles', and we have not confirmed whether it applies to accommodation. The Consumer Affairs Ministry fined 7 companies for fake Black Friday 2023 discounts, up to EUR 110,000.
Portugal: Decree-Law 70/2007 on price reductions also applies to the supply of services, 'with the necessary adaptations'. The reduction must be real against the lowest price previously charged, and the trader must be able to prove it. ASAE enforces it. The reference period was changed by Decree-Law 109-G/2021 and we have not read the current official text: check it.
Italy: since 2 April 2023, art. 17-bis of the Consumer Code requires every price reduction announcement to show the prior price, the lowest applied in the previous 30 days. Whether it covers accommodation we have not confirmed. False urgency is banned (art. 23(1)(g)) and the competent authority is the AGCM.
Greece: the Ministry told Parliament (December 2025) that art. 9i of Law 2251/1994 governs price reduction announcements and that, under the Code of Conduct on offers, the reference price is the lowest of the last 30 days; old inflated prices and recommended prices are not allowed. Whether it applies to hotels we have not confirmed.

'Only 2 rooms left': real scarcity, not invented

You may warn that few rooms are left if it is true at that moment for those dates. If the alert always shows, or counts only a small allotment you set aside for the website, it misleads. The EU network of consumer authorities (CPC) asked Booking.com (2019) and Expedia (2020) to stop suggesting artificial room scarcity and presenting as a discount something that is not. If the big platforms must do it, do it on your own site too.

Countdown timers and 'today only'

The EU directive always bans falsely stating that an offer will only be available for a very limited time to force an immediate decision (Annex I, point 7). In 2023 the Commission and the CPC network checked 399 online shops and 42 used fake countdown timers. If you show a timer, the offer must really end at that time and not come back at the same price the next day. And if you advertise 'from EUR 49', have a reasonable number of rooms at that price (Annex I, point 5, bait advertising).

Right and wrong wording

Right: 'Black Friday: 20% off our flexible rate. Was EUR 120, now EUR 96 (lowest price in the last 30 days: EUR 120). Book 27-30 November.'
Wrong: 'Was EUR 200, now EUR 96', if you never charged EUR 200 for that room in the last month.
Right: '2 double rooms left for 5 and 6 December', if your inventory confirms it at that moment.
Wrong: 'Only 2 rooms left!' fixed on every date.
Right: 'Offer valid until 1 December at 23:59', and on 2 December the price really goes up.
Wrong: a timer that resets every time the page loads, or 'today only' that lasts a week.
Wrong: '12 people are looking at this hotel', if the figure is not real.

What is coming: the Digital Fairness Act

In its 2026 work programme the European Commission announced a 'Digital Fairness Act', planned for the fourth quarter of 2026, which will address, among other things, dark patterns in website and app design. As of 9 November 2026 we have not seen an adopted proposal or its text. If it comes out, we will update this guide.

10-minute check

For every crossed-out price, check in your booking engine the lowest price for that room and rate in the last 30 days, and keep the proof.
Remove scarcity alerts that are fixed or not driven by your real inventory.
Check that every countdown has a real end date and that the offer does not repeat unchanged afterwards.
Check that the displayed price includes all unavoidable costs.
Use the same conditions on your website, your iQuota listing and every platform.

How iQuota helps

With iQuota, AI assistants read your real prices and availability through your connector, and guests book commission-free and pay at the property. If your data is real, what AI says about your offers will be real too. iQuota does not replace a legal review of your advertising.

Want an official booking page AI can read and a connector with your real prices, commission-free? The first 30 hotels join free until 30 June 2027.

See the Founding Hotels programme

Frequently asked questions

Can I show 'Was EUR 150, now EUR 99'?

Only if EUR 150 really is the lowest price you charged for that room and rate in the previous 30 days and you can prove it. An inflated 'was' price is misleading.

Does the 30-day rule apply to hotels?

We could not confirm it in an official source for every country. In Portugal the price reduction rules also cover services. In any case, a fake discount is misleading under the unfair practices directive, which does cover services.

Can I use a countdown timer on my website?

Yes, if the offer really ends when the timer hits zero. A fake countdown is banned across the EU (Directive 2005/29/EC, Annex I, point 7).

Can I say 'only 2 rooms left'?

Yes, if it is true for those dates at that moment. A fixed or invented alert is misleading.

Sources

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