Price Transparency Guidelines in Singapore: Drip Pricing, Discounts and “Free” Offers for SMEs

Short answer: Singapore’s Guidelines on Price Transparency, in effect since 1 November 2020, explain how the Competition and Consumer Commission of Singapore applies the Consumer Protection (Fair Trading) Act to prices. Mandatory fees belong in the headline price, “was” prices must be real, and “free” offers must state their conditions clearly. Breaches can lead to court injunctions.

The price transparency guidelines Singapore regulators use apply to every business selling to consumers, whether through a shop counter, a website, an app or a social media post. They are not a separate law but set out how the Competition and Consumer Commission of Singapore (CCS, which published them in 2020 as CCCS) reads the Consumer Protection (Fair Trading) Act 2003 (CPFTA). This guide covers what they expect, the CPFTA provisions behind them, enforcement, and a checklist for SMEs.

Raffles Corporate Services works with a panel of experienced Singapore law firms who offer cost-effective and efficient legal service and advice. This article is general information only and is not legal advice.

What are the price transparency guidelines in Singapore?

They are CCS’s published view of which pricing practices could breach the CPFTA, with examples and recommended good practices. Their core principle: prices and their conditions must be accurate and communicated clearly and prominently.

The Guidelines apply to all suppliers, a term defined in section 2(1) of the CPFTA, and to both online and physical retail. They do not replace the Act, and stricter sector rules prevail. The full document and a short infographic are on the CCS Guidelines on Price Transparency page.

They do not set a separate rule on per-unit pricing; the general CPFTA test (could a consumer reasonably be misled?) applies.

How do the Guidelines connect to the CPFTA?

Each example in the Guidelines is tied to section 4 of the CPFTA or a specific item in the Second Schedule. Section 4 makes it an unfair practice, in relation to a consumer transaction, to do or omit anything that might reasonably deceive or mislead a consumer, to make a false claim, to take advantage of a consumer who cannot protect their own interests, or to do anything listed in the Second Schedule.

The Guidelines’ footnotes cite Second Schedule items using numbers from the 2020 text. The current revised Act on Singapore Statutes Online numbers the same items differently, so the table below uses the current paragraph numbers.

What is drip pricing, and how should you show mandatory fees?

Drip pricing means advertising a lower headline price than the consumer will actually pay, with fees added step by step during checkout. The Guidelines say unavoidable or mandatory charges, such as taxes, surcharges and service fees, should be included in the headline price.

The CCS example is a hotel that advertises a room at S$200 a night and adds a mandatory S$100 cleaning fee on the payment page. The fee should have been in the advertised price. Points to apply in practice:

• Where a mandatory fee cannot reasonably be calculated in advance, disclose that it exists, clearly and prominently, next to the headline price.
• If payment is processed overseas, say clearly that currency conversion or cross-border fees may apply, and state any such fee you impose yourself.
• If you use pre-ticked boxes, include the add-on’s cost in the headline price and show its terms and opt-out route prominently.
• CCS recommends “opt-in” (unticked by default) or “opt-neutral” (forced yes or no) add-ons and an itemised total before payment.

GST is a separate legal requirement. IRAS requires GST-registered businesses to display and quote GST-inclusive prices on price tags, advertisements, websites and quotes. Hotels and food and beverage outlets that impose a service charge may show prices before GST if they display a prominent statement such as “Prices are subject to GST and service charge”. Details are on the IRAS page on displaying and quoting prices. If you are not sure whether you need to be registered, see our guide to compulsory and voluntary GST registration.

When is a strikethrough or “was” price allowed?

A strikethrough price is acceptable when the higher price is a bona fide previous price that you actually charged for a reasonable period in the recent, regular course of business. A price set briefly to make a later discount look larger is misleading.

The Guidelines’ example: a product usually sold at S$50 is raised to S$100 the day before a sale, then advertised at S$30 as “S$70 off”. The real saving is S$20.

1. Check the reference price: was it openly offered for a reasonable period before the sale, and recently?
2. Keep records of past prices, stock and sales so you can prove the “was” price later.
3. If you say the offer is time-limited, state the period clearly and end the promotion when you said you would. If you have a legitimate reason to change the period, amend or withdraw the advertisement quickly.
4. Use “up to”, “as low as” and “from” only if items are actually available at that price, and show the qualifier clearly next to the price.

Can you compare your prices with other sellers’?

Yes, if the comparison is true, current and like for like. The Guidelines expect you to research other sellers’ prices yourself, compare only goods or services that consumers or trade norms accept as similar or equivalent, and update or withdraw the claim when the reference price changes.

Offering a refund if a customer finds a lower price elsewhere does not excuse an inaccurate claim, and comparing your older model with another seller’s newer one without saying so omits a material fact. Keep dated records of what you compared.

When can you call something “free”?

Only when it is free in substance. The consumer must not pay for the item through a higher price elsewhere in the deal, and any condition, qualifier or later charge must appear clearly and prominently alongside the word “free”.

• Do not raise the main price to cover the cost of a free gift. The Guidelines’ example is a magazine subscription that rose from S$300 to S$410 during an offer of a “free” tablet worth S$110.
• “Free shipping storewide” with a S$200 minimum revealed only on the payment page is the Guidelines’ example of concealing a material fact.
• For free trials that convert into paid plans, remind consumers before the trial ends and explain how to cancel.

What happens if CCS or CASE finds a pricing problem?

The Consumers Association of Singapore (CASE) is the first point of contact for local consumers, and the Singapore Tourism Board (STB) for tourists. Persistent offenders are referred to CCS, which can investigate and apply to court for an injunction.

According to CCS’s overview of the CPFTA, the escalation usually runs as follows:

1. Voluntary compliance agreement (CPFTA s 8). A specified body such as CASE or STB may invite the business to sign a written agreement containing an undertaking to stop the unfair practice. It may also include undertakings to compensate consumers.
2. CCS investigation. CCS can require documents and information under Part 3A. Obstructing an investigation or giving false information can lead to a fine of up to S$10,000, imprisonment of up to one year, or both.
3. Court application (CPFTA s 9). On CCS’s application, the District Court or the General Division of the High Court may declare a practice unfair, grant an injunction (including an interim injunction) and make accompanying orders. These can require the business to publicise the injunction, tell consumers about it before contracting, state it on every invoice, and notify CCS within 14 days of changes such as new premises or websites.
4. Action against others (CPFTA s 10). CCS may also seek an injunction against a person who knowingly abets, aids, permits or procures the unfair practice.
5. Contempt. A business that breaches an injunction can be taken to court for contempt, which CCS notes can result in a fine, imprisonment or both.

Separately, individual consumers can sue under section 6 for claims up to the prescribed limit of S$30,000, and in a dispute with a consumer the business bears the burden of proving compliance with specified requirements of the Act (s 41). We cover how to respond to a customer’s claim in A Customer Threatens a CPFTA Claim in Singapore: What Your Business Should Do. If a dispute is heading towards court, speak to a lawyer.

Price transparency checklist for Singapore SMEs

Run this table against your website, listings and in-store signs before each campaign.

If you sell online, our guides to setting up an online business in Singapore and running an e-commerce business cover the wider registration, payment and tax picture. Our free tools can help with related company and tax calculations.

Frequently asked questions

Are the CCS price transparency guidelines legally binding?

Not on their own. They explain how CCS interprets the CPFTA, which is binding. A practice the Guidelines describe as misleading can be an unfair practice under section 4 or the Second Schedule of the Act.

Can we show prices before GST and add GST at checkout?

Not if you are GST-registered, unless you are a hotel or food and beverage outlet that imposes a service charge and displays the required statement. Everyone else must show GST-inclusive prices, and IRAS states that non-compliance can lead to a fine of up to S$5,000.

Can CCS fine us for drip pricing?

The CPFTA route for unfair practices is a court declaration and injunction with accompanying orders, not an administrative fine. Fines and imprisonment apply to offences such as obstructing an investigation, and to contempt if an injunction is breached.

How long should we keep pricing records?

The Guidelines set no period. Consumer claims under section 6 and CCS’s s 9 actions generally have a 2-year limitation window (s 12), so keep price and campaign records for at least that long.

Last reviewed: 2 November 2026. The Editorial Team, Raffles Corporate Services.