Key findings

  • Great Britain retail volumes rose over the three months to September 2026 but fell during September itself, a mixed backdrop that makes margin-sacrificing, broad-based discounting a poor substitute for demand diagnosis.
  • Online sales accounted for 27.5% of Great Britain retail sales in 2025, meaning a Black Friday offer is assessed across advertising, marketplaces, product pages, delivery terms and returns—not at a single point of sale.
  • Which? found that 83% of 175 tracked products were the same price or cheaper outside the four-week 2024 Black Friday sales period. The sample is not market-wide, but it illustrates why a Black Friday label alone cannot establish value.
  • CMA and ASA guidance makes price clarity and substantiation central to campaign design: retailers must be able to explain the total payable price and the basis of savings claims.
  • Sanctuary recommends a proof-of-value system that joins price evidence, total-cost presentation, availability, contribution economics and incrementality measurement before a campaign goes live.

Black Friday is now a test of value credibility

Black Friday 2026 should be approached as a test of commercial credibility rather than a single-day sales target. For retailers, brands and consumer-facing SMEs, the question is no longer simply whether a discount can generate demand. It is whether the business can show that the offer represents value, fulfil it reliably and retain enough contribution to make the demand worth winning.

The UK trading backdrop reinforces that distinction. Great Britain retail sales volumes increased by 0.7% in the three months to September 2026 compared with the preceding three-month period, but fell by 0.4% in September itself. Volumes were up on a year earlier in both comparisons, though the rate differed between the quarter and the month (Office for National Statistics, 2026) ↗. These figures do not tell an individual retailer what its own customers will do, nor can they establish the cause of changing demand. They do, however, describe an environment in which recovery and volatility coexist.

That is precisely the environment in which indiscriminate discounting becomes dangerous. A sitewide offer can bring forward purchases that would have happened later at full price; it can reduce contribution on customers who would have bought anyway; and it can teach customers that the displayed price is negotiable. The short-term revenue number may rise while the quality of demand deteriorates.

**Sanctuary’s interpretation** is that Black Friday has become a credibility test because customers now compare the whole proposition quickly: the headline price, the previous price, delivery charge, stock position, returns terms and the cost of an equivalent offer elsewhere. A campaign that relies on haste or ambiguity may still convert, but it leaves a weak basis for repeat purchase and exposes the business to avoidable complaints, returns and reputational damage.

The appropriate objective is therefore **profitable, trusted conversion**. For each major offer, leaders should be able to answer five questions: what purchase occasion does it serve; why is the saving meaningful; what will the customer pay in total; how much of the resulting demand is additional; and what evidence supports the claim if it is challenged? This is not an argument against promotions. Selective reductions can clear stock, help budget-conscious households, recruit customers and create reasons to visit local businesses. It is an argument against treating percentage-off messaging as a strategy in itself.

Digital comparison has changed the economics of a deal

The channel context makes weak claims harder to sustain. Internet sales represented 27.5% of total retail sales in Great Britain in 2025, following 27.1% in 2024 (Office for National Statistics, 2026) ↗. A shopper may encounter an offer in paid search, a marketplace listing, social content, email, a retailer’s website and a store within a short period. From the customer’s perspective, these are not separate channels with separate excuses; they are one promise made by one business.

Price history has consequently become part of the proposition. Which? tracked 175 home, technology and health-appliance products at eight large retailers for six months before and after the 2024 Black Friday period. It found that 83% were available at the same price or cheaper at least once outside the four-week Black Friday sales period (Which?, 2025) ↗. This was a bounded investigation, not a representative measure of every retailer, category or promotion. The retailers’ responses also pointed to differences in pricing models, sample size and promotional timing. Those limitations matter.

Even so, the finding identifies a material commercial risk: a Black Friday badge does not, by itself, demonstrate exceptional value. Where consumers repeatedly see a product discounted, they may update the price they regard as normal. Research on promotional exposure finds that different price claims and contextual factors affect consumers’ reference-price adaptation (Martínez-Ruiz et al., 2015) ↗. The evidence does not prescribe one universal discount frequency or depth. Its strategic relevance is directional: repeated promotional framing can alter how customers judge the undiscounted price that supports future margin.

The answer is not to insist that every Black Friday offer must be a once-a-year low. Retailers can offer legitimate value through a stock-clearance price, a bundle, a price match, a loyalty benefit, prompt collection or delivery certainty. The discipline is to say clearly which proposition is being offered and to support the associated claim. The ASA advises that comparative price claims must make their basis clear, and that RRP comparisons are likely to mislead when the RRP differs significantly from the price at which the product is generally sold (Advertising Standards Authority, 2026) ↗.

For SMEs in particular, this creates an opportunity as well as a constraint. They may not be able to outspend national competitors in paid media or match every marketplace headline price. They can, however, compete through an offer that is intelligible: a well-specified product, transparent total cost, knowledgeable advice, immediate collection, fitting, repair or straightforward resolution when something goes wrong. These are forms of value that are harder to replicate with a vague “up to” claim.

Price transparency belongs in campaign design, not only legal review

The regulatory position sharpens the operational case. The CMA’s price-transparency guidance under the Digital Markets, Competition and Consumers Act 2024 addresses the consumer journey from advertising through to purchase. Its central expectation is that consumers receive the information they need to compare offers, with mandatory fees, taxes, charges and payments normally included in the price presented (Competition and Markets Authority, 2026) ↗.

This makes the total payable price a campaign-design issue. If delivery is unavoidable, a membership is required, a threshold must be met or a bundle includes non-optional charges, those conditions change the meaning of the headline offer. A paid social advertisement, product page, basket, checkout and confirmation email should form a coherent sequence rather than progressively disclose the true cost.

The governance stakes have also risen. The CMA’s direct consumer-enforcement guidance explains its powers under the new consumer-protection regime to investigate suspected breaches, accept undertakings, and use remedies and penalties (Competition and Markets Authority, 2025) ↗. That does not imply that every error will trigger enforcement, nor does it remove the need for context-specific legal advice. It does mean that promotional substantiation should not be treated as a retrospective task for legal or customer-service teams once a campaign has launched.

There is a direct commercial mechanism here. Transparent total prices reduce late-stage surprise; clear exclusions reduce avoidable contacts and cancellations; realistic availability statements reduce the anger caused by a heavily promoted product disappearing immediately. Compliance is the minimum standard. The stronger standard is that a customer can explain, without decoding footnotes, why the offer was worthwhile.

For high-street businesses, this is also a productivity issue. Store colleagues should not have to repair unclear online propositions at the counter or explain conditions that were omitted from campaign creative. A small investment in clear offer architecture and staff briefing can reduce rework, protect service time and make in-person interactions more valuable.

The proof-of-value system: evidence, economics and accountability

**Sanctuary recommendation.** Retailers should create a proof-of-value record for every hero offer and every campaign-wide saving claim. It need not be complex. A smaller business can use a controlled spreadsheet and named approval owner; a larger organisation can draw the record from product, pricing, ecommerce and finance systems. What matters is a shared evidence layer across merchandising, marketing, operations, customer service and finance.

The record should include seven elements:

1. **Offer purpose.** Identify the product or service and state its intended job: acquisition, reactivation, stock clearance, trade-up, gift conversion, local footfall or retention. A campaign cannot be evaluated sensibly if its purpose is undefined.

2. **Price proof.** Record the prior selling price and relevant dates, RRP evidence where it is used, the basis for any competitor comparison or price match, and the accountable approver.

3. **Total-cost journey.** Map the price shown at discovery, product page, basket, checkout and confirmation. Include delivery, mandatory add-ons, spend thresholds, return costs, finance terms and membership conditions.

4. **Availability proof.** Record stock, channel allocation, geographic limits, replenishment expectations and substitution rules. A scarce line should not imply a broad saving that customers cannot reasonably access.

5. **Contribution case.** Estimate contribution after product cost, fulfilment, payment fees, expected returns, paid media and incremental customer-service demand. Gross sales and conversion rate are insufficient measures of success.

6. **Incrementality design.** Define the counterfactual before launch: a holdout group, matched geography, customer cohort or pre-specified comparison period. No method is perfect, especially for a seasonal event, but the business should estimate how much demand was additional rather than assuming all event-period revenue was caused by the campaign.

7. **Learning record.** Compare forecast with actual redemption, margin, cancellations, returns, complaint themes, repeat purchase and subsequent full-price demand. This turns Black Friday from an annual scramble into a source of usable pricing intelligence.

This framework separates facts from judgement. The price history and conditions are evidential questions; the appropriate discount depth, stock allocation and media ceiling are commercial judgements. Bringing them together makes those judgements more accountable.

It also prevents a common measurement failure. A campaign may look successful because sales increase during a period when consumers expected to buy anyway. Equally, a carefully targeted offer may look modest on top-line revenue but create valuable new-customer demand or release working capital from slow-moving stock. The purpose of incrementality measurement is not to manufacture a precise answer from imperfect data. It is to prevent executives from mistaking seasonal correlation for promotional effectiveness.

Urgency remains useful—but it must be proportionate to the proposition

A credible counterargument is that retail needs urgency. Consumers often defer planned purchases to November, suppliers may support event pricing, and a deep reduction can unlock aged stock or make a major purchase affordable. Refusing to participate in Black Friday is not inherently more strategic than participating. The question is whether the urgency is proportionate to a real and intelligible offer.

A limited stock-clearance line can justify a time-bound reduction. A genuine delivery cut-off can justify a deadline. A carefully controlled loyalty offer can reward a defined customer group. By contrast, an evergreen “was/now” cycle risks weakening the credibility of the reference price, while a mandatory delivery charge revealed late in the journey conflicts with the CMA’s emphasis on clear, comparable prices (Competition and Markets Authority, 2026) ↗.

A useful internal test is simple: would the business be comfortable publishing the price history, total delivered price, material conditions and stock allocation alongside the creative? If not, the offer may be relying too heavily on friction, ambiguity or customer haste.

The practical preparation sequence is therefore short but demanding. In the first week, reduce the number of offers and remove those with weak price evidence, unclear availability or inadequate contribution. In the second, test the full customer journey on mobile, desktop, marketplaces and store materials, and equip frontline colleagues with a plain-English offer brief. In the final week, set contribution floors, stock stop-rules, media ceilings and the measurement approach; then plan the December transition so customers are not immediately trained to expect another discount.

The broader lesson is that value is a proposition, not a percentage. In Black Friday 2026, the retailers best placed to protect margin, trust and local economic value will be those that can substantiate the saving, reveal the total cost early and distinguish profitable additional demand from sales that merely arrived sooner.

Sanctuary proof-of-value system for promotional campaignsOriginal Sanctuary conceptual framework. It is an operating model, not a quantified evidence claim.
Customer job and offer purpose
Price and comparison evidence
Total-cost presentation
Stock and fulfilment availability
Contribution and incrementality guardrails
Post-event learning and customer recovery

Research foundation

References

  1. Office for National Statistics (2026). Retail sales, Great Britain: September 2026. Office for National Statistics.
    Source ↗
  2. Office for National Statistics (2026). Internet sales as a percentage of total retail sales (ratio) (%). Retail Sales Index time series.
    Source ↗
  3. Which? Editorial Team (2025). Don’t believe the hype: Most Black Friday deals the same price or cheaper at other times of the year, Which? finds. Which? Policy and Insight.
    Source ↗
  4. Competition and Markets Authority (2026). Unfair commercial practices: price transparency (CMA209). GOV.UK.
    Source ↗
  5. Competition and Markets Authority (2025). Direct consumer enforcement guidance: CMA200. GOV.UK.
    Source ↗
  6. Advertising Standards Authority and Committee of Advertising Practice (2026). Prices: General. ASA and CAP AdviceOnline.
    Source ↗
  7. Martínez-Ruiz, M. P., Blázquez-Resino, J. J. and Pino, G. (2015). Interaction effects of different price claims and contextual factors on consumers' reference price adaptation after exposure to a price promotion. Journal of Retailing and Consumer Services, 27, 63-73.
    Source ↗DOI: 10.1016/j.jretconser.2015.07.005
  8. Basher Eyre. Hero image: Shoppers in the High Street - geograph.org.uk - 3604658.jpg. Wikimedia Commons · CC BY-SA 2.0.
    Image source ↗

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