In mid-2025, Law 473 of June 19, 2025 was published in the Official Gazette, amending Law 45 of 2007 on Consumer Protection, particularly with respect to the concept of the “total price” of products, goods, and/or services made available to consumers.

Only a few weeks ago, Executive Decree No. 2 of January 23, 2026 was issued, amending provisions of the Regulations of the Consumer Protection Law and further developing the rules introduced by Law 473 regarding total price disclosure.

WHAT DOES THIS NEW REGULATORY FRAMEWORK PROVIDE?

Definition of Total Sale Price

The regulation defines the total sale price as the final amount that the consumer must pay for a product, good, and/or service, including legally established national taxes and/or fees.

Obligation to Display the Total Price

All establishments and sales channels offering products, goods, and/or services must clearly and visibly indicate to consumers the total price of the items offered.

This total price must correspond to the amount the consumer is required to pay, except in cases where additional charges apply. Such additional charges must be clearly disclosed, both as to their nature and amount. These may include, for example:

• Late payment charges
• Payments to third parties
• Insurance premiums required as a condition of contracting

Mandatory Informative Notice

Economic agents must include in their establishments or sales channels (in our view, including e-commerce websites) a notice stating that applicable taxes and/or fees are included in the total price of the product, good, and/or service.

This notice must be displayed in a visible location prior to the consumer completing payment.

Clarity Standards in Price Display

Merchants are required to clearly announce the total price of their products, goods, and/or services, ensuring that such prices are properly differentiated and displayed using sizes, colors, and backgrounds that allow for adequate readability at an average viewing distance.

IMMEDIATE ACTIONS

As explained in our previous publication, these changes will enter into force on June 19, 2026, one year after the enactment of Law 473. Accordingly, fewer than six months remain for economic agents to fully comply with this regulatory framework.

In light of the new regulation, we recommend that merchants:

• Identify appropriate physical spaces within their establishments to display the legally required notice.
• Coordinate with their technology advisors to implement the required notice on the website or digital platform through which products, goods, or services are commercialized.
• Review their accounting systems and procedures to ensure proper control of total prices within their inventory, thereby providing consumers with the experience required by law, maintaining orderly accounting records, and complying adequately with their tax obligations.

The General Directorate of Revenue (Dirección General de Ingresos – DGI) has communicated that the amendments introduced by Law 473 do not modify the format or content of the fiscal invoice issued to the purchaser. Accordingly, fiscal invoices will continue to be issued in the same manner as at present.

At FABREGA MOLINO, we advise economic agents across multiple industries on the proper structuring of their day-to-day operations in compliance with applicable legal provisions. Should you have any questions regarding this new regulatory framework in consumer protection matters, we invite you to contact us so that we may provide appropriate guidance.