Countdown timers, reviews and discounts: what the ACM allows

Pressure works, and that's why there are rules

Countdown timers, "only 3 left" and "12 people are viewing this" are everywhere. They work, because people don't want to miss out. That's exactly why the ACM, the Dutch Authority for Consumers and Markets, keeps an eye on them. A trick that works because it seems true is misleading when it isn't true.

This article lists the nine best-known tricks, with what you can do instead. It isn't legal advice. If you're unsure about your own situation, read the ACM's guidelines or ask a lawyer.

1. Fake urgency

A countdown timer that restarts every day, an offer that "ends today" but is still there tomorrow, a stock counter that doesn't really count. A false time limit is on the European blacklist: it's always banned.

In June 2023 the ACM checked webshops and found 41 offers that simply carried on after the timer hit zero. Dozens of shops were told to stop.

What is allowed: real urgency, with the reason attached. "Registration closes on 1 March, the course starts on 3 March." Or: "October is nearly full, 3 spots left."

2. Fake reviews and trust marks you don't hold

Since 28 May 2022, fake reviews are banned under all circumstances. That includes reviews you buy, have written, or leave out selectively. Showing a trust mark (keurmerk) you don't hold is banned too.

It isn't only a legal risk. In research by Motivaction, 55% of Dutch online shoppers said they only buy where the reviews are trustworthy.

What is allowed: real reviews with source, date and a line about how you collect them. Read more in reviews on your website.

3. Hidden costs

Costs that only appear at the last step, or sit behind a small info icon. The ACM is clear: you state the total price from the first moment, including with a from-price.

What is allowed: a price including VAT and all mandatory costs, before anyone fills in a form or checks out.

4. Fake was-now prices

"Was €199, now €149", when the product never cost €199. For products, the was price must be the lowest price of the past 30 days. In June 2024 the ACM fined five webshops a combined €621,000 for sham discounts.

What is allowed: a real previous price, or simply no comparison.

5. Pre-ticked boxes

A box that's already ticked for a paid extra, a newsletter or cookies. According to the ACM, a customer doesn't even have to pay for a paid extra that ends up in the order this way.

What is allowed: an empty box with a clear text next to it.

6. Guilt and endless nagging

"No, I don't want a discount." Or a cancellation page that asks five times whether you're sure. Anyone who can take out a subscription online must also be able to cancel it online, just as easily.

What is allowed: a neutral button: "No, thanks."

7. Disguised ads and fake chat agents

Advertising must be recognisable as advertising. And a chat window showing "Sanne is typing" when nobody is there breaks trust the moment the visitor notices.

What is allowed: labelling sponsored content, and a chatbot that says it's a bot, with a route to a person.

8. An unfair cookie banner

A bright "Accept" button and a grey "Settings" link where you can only decline after three clicks. In 2025 the Dutch Data Protection Authority warned more than 200 organisations about this.

What is allowed: "Accept" and "Decline" equally clear on the first layer. And if you don't use tracking that needs consent, you don't need a banner at all.

9. Conditions in small print

A condition that's smaller, lighter or further away than the offer itself, because it might slow down sales. The ACM names this explicitly.

What is allowed: the condition as large as the offer, in one clear line.

Honest works too

One thing business owners often forget: honest urgency works just as well as fake urgency. The difference is that you can never be caught out. And for a local business that lives on word of mouth, being caught out costs more than any fine. One discovered trick makes all your reviews, guarantees and promises look suspect.

In short

• Urgency and scarcity only when true, with the reason attached.
• No fake reviews, no trust marks you don't hold.
• The total price from the start, including VAT for consumers.
• No pre-ticked boxes, no guilt, a fair cookie banner.

Every site we build is checked against these rules before it goes live. This is how website design at Webclouds works.