Timestamping: Prove Price Compliance With Omnibus Directive

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In an era marked by digital advancements and rapid technological innovation, ensuring transparency and accountability within financial markets has become an increasingly complex challenge. Governments and regulatory bodies around the world strive to maintain fair and efficient market conditions, guaranteeing that pricing information is accurate, reliable, and compliant with established guidelines. To tackle this critical issue, a powerful tool has emerged: timestamping.

Timestamping: Prove Price Compliance With Omnibus Directive
Timestamping: Prove Price Compliance With Omnibus Directive
Table of contents

Strengthening Consumer Protection: The Omnibus Directive

Introduced on May 28, 2022, the European Union implemented a robust regulatory measure known as the Omnibus Directive. This transformative directive significantly enhances the penalties associated with deceptive promotions, insincere reviews, and aggressive door-to-door sales.

The key objective of the Omnibus Directive is to bolster the protection of consumers, particularly those reliant on digital platforms or marketplaces for their purchasing needs. In the rapidly growing digital economy, where the consumers often face challenges in ascertaining the credibility of products, services, or the marketplace itself, the directive provides a necessary safeguard.

The Omnibus Directive tackles three primary commercial practices that potentially compromise consumer rights, but today we are focusing in on the last of these: proving price compliance.  Aimed at enhancing transparency in pricing, the directive forbids false promotions. Sellers must indicate the product's price before applying a discount, which must correspond to the lowest price charged during the preceding 30 days. Continuous violation of this provision can result in a two-year imprisonment and a fine of €300,000.

These rules usher in a new era of consumer protection, where the onus is on businesses to maintain transparency and authenticity in their operations. Non-compliance isn't just risky; it can potentially disrupt businesses and their reputation in the market.

Timestamping: An Effective Solution for Price Compliance

In this context, timestamping emerges as an efficient tool to prove price compliance. It involves recording the date and time of an event in a secure manner, providing an unalterable record.

For e-commerce businesses, applying timestamping to price changes can ensure adherence to the Omnibus Directive's stricter rules on misleading promotions. The directive stipulates that the seller must indicate the product's price before applying a discount. This previous price should correspond to the lowest price charged by the seller during the 30 days preceding the discount.

With timestamping, businesses can easily verify and demonstrate that the discounted price and the original price adhered to this rule. Timestamping can effectively prove that the original price was indeed the lowest price charged in the previous 30 days, thus preventing deceptive promotional practices.

Understanding the Mechanism of Proving Price Compliance

Timestamping, as a technology, leverages the principles of cryptography to provide a secure and accurate record of time for a specific event or transaction. Here's a more detailed look at how it functions:

1. Hash Function

When an event occurs, like a price change in an online marketplace, the details of that event are put through a cryptographic hash function. This hash function takes an input (or 'message') and returns a fixed-size string of bytes, typically a hash 'digest' that is unique to each unique input. It's virtually impossible to reverse-engineer the original input from the hash digest.

2. Timestamp Authority (TSA)

This hash digest is then sent to a trusted third-party entity called a Timestamp Authority (TSA). The TSA generates a timestamp that includes the current date and time.

3. Digital Signature

The TSA combines the hash digest with the timestamp and then uses its private key to sign this data, creating a digital signature. This signature confirms the TSA's endorsement of the timestamp.

4. Return to Originator

The digital signature, which now contains the original hash digest and timestamp, is returned to the originator and can be stored as proof of the event.

The digital timestamp proves that certain data (in this case, the price change) existed at a particular point in time. In the context of the Omnibus Directive, this timestamped record can prove that a price was changed at a specific time, thus ensuring that any price reductions meet the required 30-day lowest price rule.

The critical point is that the data linked to the timestamp cannot be altered; any changes to the data would produce a different hash digest. Therefore, the use of timestamping provides a highly secure, tamper-proof method of recording the time of an event or transaction. Its applications in e-commerce platforms ensure transparent operations, trustworthiness, and enhanced consumer protection.

Penalties & Enforcement of the Omnibus Directive

The directive imposes heavy fines and even imprisonment for violating these rules, ensuring stringent compliance. The maximum fine for abuse of terms is now €15,000 for individuals and €75,000 for businesses. In cases of large-scale infringement, the fine can go up to 4% of the company's average annual turnover calculated over the last three known annual turnovers.

The French Directorate General for Competition, Consumer Affairs, and Fraud Control (DGCCRF) will monitor the observance of these new rules, particularly during price reduction operations such as sales or "Black Friday" events.


Adherence to the Omnibus Directive is crucial for businesses to maintain their reputation and customer trust. With the assistance of timestamping, businesses can reinforce their commitment to transparency and fair trade, fortifying consumer protection in the digital age.

Digital integrity and transparency are no longer optional – they're mandatory in our evolving digital economy. By embracing innovative solutions like timestamping, businesses can prove their adherence to regulatory guidelines, thereby improving their reputation and trustworthiness in the digital marketplace.

In the Omnibus Directive era, timestamping isn't just a tool – it's a solution for digital fairness and price compliance.



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Philippe ThomasPhilippe is the CEO of Vaultinum. An expert in new technologies and high finance, and after 20 years in the international fintech industry, Philippe now heads Vaultinum.

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