What the CMA published on 5 October

The Competition and Markets Authority updated the Simba Sleep consumer protection case page on 5 October 2026 with a short entry: on 22 September 2026 it had accepted minor revisions to the undertakings the mattress company signed in 2024, and it is satisfied that the changes continue to address the concerns they were designed to address. The revised undertakings run to a 72KB PDF. The case remains closed, and the outcome is still recorded as consumer enforcement by undertakings.

The CMA did not describe which clauses moved, and it did not say why Simba asked for the revision.

Why the mattress pricing principles left the shelf

About ten weeks earlier, a different case changed the guidance behind these prices. On 30 July 2026 the High Court handed down its judgment on Emma Sleep's use of 'was/now' pricing, also called reference pricing. The CMA's case page records that the court found Emma Sleep had infringed the law in relation to a number of admitted breaches, but did not make further findings of infringement, and that the court has invited the CMA and Emma Sleep to work together to agree the terms of a further order.

While the CMA considers the judgment and its next steps, it has temporarily withdrawn the online mattress sales guidance. The GOV.UK page that hosted the discount and reference pricing principles for selling mattresses online now carries a withdrawal notice dated 30 July 2026. A document written specifically for the mattress sector is therefore no longer the CMA's published position, and no replacement date has been given.

The general guidance that applies to any online trader is a separate document, and it is still on the site.

What Simba still has to do

The undertakings themselves were not withdrawn. When the CMA accepted them in July 2024, Simba committed to two main sets of rules. On discount claims, it must ensure that any 'was' price is genuine, meaning that it actually sells a sufficient volume of the product at that higher price over a sufficient period before using it as a comparison. On countdown clocks, any clock on its websites must be clear, must specify prominently which products it applies to, and must not give consumers a false impression that they have to act quickly, or that the product will revert to the 'was' price when the clock ends if that is not the case.

The commitments also carried a reporting duty: Simba had to give the CMA a compliance report within six months of signing. The company said at the time that it believed it was already compliant, and it had until 9 September 2024 to have its internal compliance processes fully operational.

A blank mattress price tag and sales receipts sit beside an unnumbered clock and a blank product card.
Concept illustration of two continuing commitments: a genuine comparison price supported by real sales, and a clear product-specific countdown. No retailer, actual price or compliance finding is shown.

The numbers behind the rules

The 2024 press notice published the evidence that worried the CMA: across various periods sampled between 2021 and 2023, using evidence from four companies, Company A sold only 7.7 percent of its mattresses at or above the quoted reference price, Company B 1.6 percent, Company C 5.5 percent, and Company D 0.9 percent. The CMA's view was that using a reference price based on such low comparative volumes is likely to be misleading.

The same notice set out two practical tests. Retailers in the sector should not describe a product as on sale with a 'was' price for longer than it was offered at that 'was' price, and they should stop using the 'was' price once they have sold twice as many items in the sale as they sold at the higher price. Both tests sat in the principles document that is now withdrawn, so they are no longer published as the CMA's sector guidance, even though the evidence behind them has not been retracted.

What still applies to any online seller

The March 2023 open letter on urgency and price reduction claims is still live on GOV.UK. It explains how businesses must be transparent when they make urgency claims, such as countdown timers and scarcity messages, and price reduction claims that refer to a higher comparison price. It is addressed to online retailers, marketplaces, intermediaries and the businesses that build their stores.

The Digital Markets, Competition and Consumers Act 2024 sets the penalties. The CMA's price transparency guidance, published in November 2025 and summarised in January 2026, explains the relevant parts of the Act. It states that a trader found to have broken the law could be fined up to 10 percent of its turnover, or £300,000, whichever is greater, and could be ordered to compensate affected customers.

Shoppers can report a problem to the CMA as well as read the guidance. The CMA runs a service for reporting a consumer protection problem, and the CMA's press notice on the Simba case records two Advertising Standards Authority rulings against the company, on 21 September 2022 and 6 March 2024, in which complaints about misleading pricing claims were upheld.

What the update leaves unpublished

The CMA does not summarise the minor revisions it accepted on 22 September 2026, so a reader who wants to know which commitments changed has to open the undertakings PDF. There is no published date for republishing the mattress principles. The High Court's invitation to agree a further order had not produced a published order when the CMA's case page was read.

The CMA's own site is also inconsistent on this point. The consumer protection guidance collection still lists the mattress pricing principles in its sector table as guidance for businesses, while the page it links to says the publication was withdrawn on 30 July 2026.

Two things did not change. The withdrawal of the mattress principles did not cancel Simba's undertakings, and the general rules on urgency and price reduction claims are unchanged. What changed is which document the CMA currently points the mattress sector to.