Key takeaways
- 11 of 21 checkouts: discount or free delivery conditions only in a footnote or the terms. A condition that changes the price belongs where the price is shown, not one level deeper.
- 8 of 22 checkouts: delivery charge not shown where the price is first seen. The total price, including every charge the customer has to pay, belongs in the headline price.
- No new screen needed: each of the 5 findings is a label, a line or the order of a step.
What we saw across 24 checkouts walked
Each finding with the screen it sits on, the rule it touches and how big a change usually is (S label or text, M layout or order, L new screen or route). Walked against the full Flowlane checklist for the United Kingdom (16 checks); shown here: every finding that came up in more than one flow. Each number counts only the flows in which that step could be checked.
Every rule chip opens its card on the rules page.
| What we saw | Flows | Rule (market rules) | Change |
|---|---|---|---|
| Discount or free delivery conditions only in a footnote or the termsWhere it sits: Header banner, sign-up pop-up, promotion terms | B · DMCC s 230 B · DMCC s 230In force since April 2025 Total price up frontThe price shown includes every charge the customer has to pay. Read the rule, with examples →A condition that changes the price belongs where the price is shown, not one level deeper. | MMedium | |
| Delivery charge not shown where the price is first seenWhere it sits: Product list, product page tabs, basket | B · DMCC s 230 B · DMCC s 230In force since April 2025 Total price up frontThe price shown includes every charge the customer has to pay. Read the rule, with examples →The total price, including every charge the customer has to pay, belongs in the headline price. | SSmall | |
| Subscribe and save, larger size or dearer delivery preselectedWhere it sits: Product page, basket delivery options | B · CCR reg 40 B · CCR reg 40In force since 2014 Paid extras need a clear yesNo paid extra without a deliberate yes; pre-ticked is not a yes. Read the rule, with examples →No additional payment without the customer's express consent; a pre-ticked box is not consent. | SSmall | |
| Refusing cookies takes more effort than accepting themWhere it sits: Cookie banner on the first page | D · PECR reg 6 D · PECR reg 6In force; amended February 2026 Cookies wait for a clear choiceNon-essential cookies need consent first; refusing is as easy as accepting. Read the rule, with examples →Refusing non-essential cookies is as easy as accepting them, on the same layer; advertising cookies wait for a clear yes. | MMedium | |
| Marketing email box ticked before the customer types an addressWhere it sits: Checkout contact step | D · PECR reg 22 D · PECR reg 22In force since 2003 Marketing emails need a clear opt-inNo marketing emails or texts without consent; a pre-ticked box is not consent. Read the rule, with examples →A pre-ticked box is not consent to marketing; where the existing-customer route is used, a clear opt-out belongs here. | SSmall |
Three examples
Written as categories, no company identifiable.
Offers
In one checkout, the header offered up to 15% off the first order; that the 15% needs an order of £100 or more and excludes sale items appeared only at the bottom of the page.
Fees
In one checkout, a product of about £90 showed only a delivery time beside the price; the about £7 delivery charge sat in a closed tab and appeared again at checkout.
Defaults
In one checkout, the product page opened with the subscription already selected instead of the one-off purchase, at about 10% off, with a delivery every two months.
What the rules ask
The pricing and unfair-practice rules have applied since 6 April 2025. Shown here: the rules this report touches.
Fees and total price
The total price, including every mandatory charge, in the headline price. No additional payment without the customer's express consent, so nothing pre-ticked.
Consent
Non-essential cookies and marketing messages wait for a clear yes; refusing is as easy as accepting.
Check your own flow in ten minutes
One question per finding. A "no" is worth a look; it is not a verdict.
Not observed in this benchmark
What a public walk cannot show. Not part of the benchmark; included in a Flowlane review of your own flow.
Card surcharges and the payment step
The walk stopped before payment, so anything shown after card details are entered stayed out of view.
Included in a Flowlane review
We walk the payment step with a test card.
Returns and refunds
A guest walk ends before an order is placed, so returns and refund screens are never reached.
Included in a Flowlane review
We check the returns flow on a test order.
Member prices and signed-in checkouts
Every checkout was walked as a guest, so loyalty prices and saved account details were not tested.
Included in a Flowlane review
We walk it with a test account you provide.
Method and anonymity
Same walk, same checklist, same rule mapping for every sector.
Public flows, walked as a guest
Each flow was walked in a desktop browser set to the market's language, time zone and storefront, from the entry page to the last screen before payment or personal data. Cookie banners were read before the first click and spot-checked from the market; banners shown only to visitors from other countries were left out. Nothing was bought, no account was created, no personal data was submitted.
One screenshot per observation
An observation counts only with a screenshot, the URL, the step number, the date and the exact wording on the screen. Uncertain observations are not counted.
Rule, not verdict
Each pattern is matched to the provision it touches. It marks a screen worth a look, not a legal finding: whether a rule applies depends on facts a public walk cannot see.
Anonymous by design
No company is named, quoted or identifiable. Examples are written as categories. The sample is drawn from the sector, not from clients, and no participant was told.
20-minute walkthrough
Your own flow against 24 walked flows, in 20 minutes.
- 20 minutes
- Reviewed before the call
- No system access
- The two steps worth a look first, with the screen they sit on
- The rule each one touches, under the UK rules
- Where your flow sits against the sector benchmark, for you only