Below-MRP sale checklist: prices, labels and evidence

Check current price against verified MRP

For the below-MRP display, confirm current selling price < verified MRP for every included variant. In a simple example, ₹799 < ₹1,299 meets that condition. Then establish the relevant historical prior price separately—₹899 in this example—and label all three amounts clearly.

This first check describes ComplyCat’s display approach. The legal requirement still concerns an announced price reduction. The “before” reference window describes the source history, not a requirement to show the label before the discount is communicated.

Sources: Official Gazette: 2026 amendment, rule 4(13) · PIB explanation of the announcement-based window

Lock the announcement time before calculating the reference

From 1 January 2027, rule 4(13) requires the prior price alongside an announced reduced price. The government identifies prior price as the lowest offered price during the 30 days preceding the announcement. A later sale start should not silently replace that anchor.

For a fictional campaign, assume a storefront banner first announces “₹799 from 2 February” at 00:00 IST on 31 January 2027. The sale starts at 00:00 IST on 2 February. Use the preceding period from 00:00 IST on 1 January up to, but not including, 00:00 IST on 31 January for that announcement—not 3 January to 2 February. The explicit timezone avoids a different window being chosen by a scheduler running in UTC.

Record the first publication planned across the storefront and other campaign materials. If a proposed earlier teaser already communicates a reduction, review that timing before approval. Keep the product and variant list attached so a broad headline does not outrun the evidence for individual offers.

Sources: Official Gazette: 2026 amendment, rule 4(13) · PIB explanation of the announcement-based window

Give every approval check an owner and an artefact

The following is a suggested operating checklist, not a government-prescribed approval form. One person may hold several roles; what matters is that no check falls between teams.

Test the rendered claim, not just the admin settings

On Shopify, the way Price and Compare-at price appear on product and collection pages depends on the theme. Variant inconsistencies can affect collection sale displays, and checkout shows only the sale price. Approving the product data alone therefore misses how a badge or label reaches the shopper.

Check that the prior and reduced prices appear together, that any MRP reference is separately understandable and that savings arithmetic uses the stated denominator. Select each advertised variant: a switch should not leave a previous variant’s comparison on screen. Review cropped mobile banners and collection cards as well as the full product page.

Sources: Shopify Help Center: sale-price presentation and variants

Decide what blocks launch

A missing interval in the history, an unexplained minimum or a mismatch between a banner and its product page should be an explicit review item. Do not mark it complete merely because the pricing app reports success. Investigate the evidence or revise the proposed claim before approval.

Short-history products, coupons, loyalty and bank offers, bundles, different markets and progressive reductions need documented treatment; the cited materials do not resolve all of them. An earlier campaign calculation should not be reused for a later cut without review. Existing dark-pattern rules also apply to urgency messages and other promotional design.

Sources: Official Gazette: 2026 amendment, rule 4(13) · Guidelines for Prevention and Regulation of Dark Patterns, 2023

Close the loop after publication

Name someone to compare the published campaign with the approved version and handle mismatches promptly. Preserve the original announcement, supporting calculation and any corrections rather than overwriting the decision record. This recommended evidence trail is not a prescribed retention period. If publication is delayed or brought forward, revisit the window and approval before the changed announcement goes out.