Yes, UK retailers can set an expiry date on gift cards. There is no fixed statutory limit under the Consumer Rights Act 2015, but the term must be fair and clearly disclosed. Three things to sort first: show expiry at the point of sale, set your EPOS up to track VAT and balances correctly, and write down how long you keep voucher data and why.
TL;DR:
- Retailers can set expiry dates on gift cards as long as they are fair and clearly disclosed at the point of sale, on the card, and on receipts or online.
- Expiry details must be visible on the card face, till screen, receipt, and at checkout, with QR codes or short URLs accepted for limited space.
- VAT must be tagged correctly in the EPOS system, with single-purpose vouchers triggering VAT at sale and multi-purpose vouchers deferring VAT until redemption.
- Changes to expiry policies on live vouchers require careful backup, staff briefing, and reconciliation to prevent accounting or customer service errors.
- When a business becomes insolvent, vouchers are treated as unsecured claims, and redemption policies may change based on company discretion during administration.
Table of Contents
- The legal baseline: fairness, not a fixed expiry limit
- Where and how to show expiry information to customers
- VAT treatment: single-purpose and multi-purpose vouchers
- EPOS settings to check before you go live
- What happens to vouchers if the business becomes insolvent
- Data protection duties for voucher records
- Seven changes to make at the till this week
- Changing expiry settings in your EPOS without breaking anything
- Balancing legal caution with a system that still feels simple
- How Switch&Save makes compliant gift card handling straightforward
- Sources
- FAQ
The legal baseline: fairness, not a fixed expiry limit
There’s no law that says a gift card must last exactly 12 months, or 2 years, or any set period. What the Consumer Rights Act 2015 does say is that any term causing a significant imbalance between you and your customer can be challenged as unfair. A very short expiry buried in the small print is exactly the kind of term that fails that test.
The DMCC Act and CMA guidance add another layer: expiry counts as “material information”, and leaving it out of your invitation to purchase can be treated as an unfair practice regardless of whether it actually changed anyone’s decision. That’s a strict standard, and it’s worth building your processes around it rather than hoping nobody notices a gap.
Practices that tend to get flagged include:
- Setting an expiry of a few weeks with no clear warning at sale.
- Burying the expiry clause in lengthy terms nobody reads.
- Changing the expiry period after the card has already been sold.
Keep the wording plain, keep it visible, and keep it consistent once a card is issued.
Where and how to show expiry information to customers
Material information has to reach the customer at the right moment, not just exist somewhere on your website. Under CMA guidance, that means expiry, fees, redemption rules and who’s actually supplying the card all need to be clear before someone commits to buying.
- Print the expiry (or “no expiry”) clearly on the card face or back.
- Show it again on the till screen at the point of sale.
- Include it on the printed or emailed receipt.
- Repeat it on the online product page and again at checkout.
- Where card space is tight, add a QR code or short URL linking to the full terms, which the CMA accepts as a reasonable alternative; you can find services for both physical and digital gift cards via Craftsuprint Gift Vouchers.
A simple line like “Valid for a reasonable period from purchase, see [shortlink] for full terms” covers most of this in a handful of words. Consistency across card, till and web copy matters more than clever phrasing.
VAT treatment: single-purpose and multi-purpose vouchers
HMRC’s voucher guidance splits vouchers into two categories, and which one applies changes when VAT is actually due. A single-purpose voucher, where the VAT rate is fixed and known at the point of sale, triggers VAT at that point. A multi-purpose voucher, where the rate can’t be determined until redemption (a general gift card usable across mixed-rate items, for instance), defers VAT until it’s actually redeemed.
That distinction has to live inside your EPOS, not just in your accountant’s head.
- Tag every voucher sale as single-purpose or multi-purpose at the point of issue.
- Defer VAT recognition on multi-purpose vouchers until redemption, not at sale.
- Record the tax rate applied at redemption against each transaction.
- Run a redemption report after each period to confirm VAT was accounted for at the right rate and the right time.
Getting this wrong doesn’t just create an accounting headache, it can misstate VAT owed for a period where nothing was actually spent.
EPOS settings to check before you go live
Before you touch expiry rules, walk through your EPOS configuration properly. Most systems have the fields you need, they just aren’t switched on by default.
- Confirm the expiry date field exists on voucher products and is editable per batch.
- Enable remaining balance tracking so partial redemptions show correctly.
- Turn on partial payment support so a voucher can cover part of a bill.
- Set VAT tagging for single-purpose versus multi-purpose vouchers.
- Switch on audit logging for every voucher issue, redemption and override.
- Check online gift-code imports sync correctly with in-store balances.
- Set staff permission levels so only authorised users can override expiry or balance.
- Update receipt templates to display expiry date and remaining balance.
Pro Tip: Test every change in a sandbox environment first, and run a full reconciliation report before pushing it live in your actual till network.
Our guide on setting up gift cards in your EPOS walks through the redemption side of this in more depth.
What happens to vouchers if the business becomes insolvent
Vouchers are generally treated as unsecured claims in an insolvency, according to the Law Commission’s review of consumer prepayments. Honouring an outstanding balance during administration is usually a commercial choice, not a legal duty, which puts the decision squarely on the business and its administrators.
- Build a honour or reject toggle into your EPOS so redemption policy can change quickly if needed.
- Use conditional redemption rules to allow partial payment against a voucher balance rather than an all or nothing approach.
- Publish a clear notice on your site and at tills if administration occurs, stating the current redemption position.
- Keep transaction evidence available for customers who pursue a card issuer chargeback or Section 75 claim.
Data protection duties for voucher records
Voucher data is still personal data once it’s tied to a purchaser, and the ICO’s storage limitation guidance requires you to justify how long you keep it.
- Write down a retention period for each category of voucher data, tied to a specific purpose (VAT records, chargeback evidence).
- Keep VAT and accounting records for as long as your statutory bookkeeping obligations require, and no longer for personal data attached to them.
- Automate deletion or anonymisation once the justified period ends.
- Build an export function for subject access requests and audits directly into your EPOS.
Seven changes to make at the till this week
You don’t need a system overhaul to close most of the gaps above. Start with these:
- Add the expiry date to the card face or back.
- Print expiry on every receipt.
- Add a checkout banner or QR code linking to full terms.
- Give till staff a short script for expiry questions.
- Configure VAT tagging correctly in your EPOS.
- Enable balance display on receipts and the till screen.
- Schedule a weekly reconciliation report.
Run a mystery shop across a few tills in week one, then check the reconciliation reports weekly for the first month to catch anything that slipped through. Our receipt VAT checklist has ready wording you can adapt for cards and till displays.
Changing expiry settings in your EPOS without breaking anything
Changing an expiry policy on live vouchers is a change to outstanding customer liabilities, so treat it with the same care as any financial system change.
- Take a full backup and pull a list of every outstanding voucher and its balance.
- Notify your accounts team and customer service before making changes.
- Update the voucher product settings in your EPOS.
- Update receipt templates and web copy to match.
- Run a reconciliation and validation pass across a sample of live vouchers.
- Notify staff of the change and brief them on customer queries.
- Keep the audit log from before and after the change in case you need to roll back.
If anything looks wrong in reconciliation, roll back to the backup before the change goes any further.
Balancing legal caution with a system that still feels simple
Retailers that get this wrong usually aren’t being careless, they’re using an EPOS that makes clear disclosure harder than it should be. A system that lets you tag VAT correctly, show balances plainly and log every override removes most of the guesswork. Single-site rollouts of these changes typically take a day or two; multi-store operators need longer to test receipt templates and staff scripts across every location before going live everywhere at once.
— Amir
How Switch&Save makes compliant gift card handling straightforward
You shouldn’t need a legal team on standby every time you sell a gift card. Some EPOS bundles include expiry and balance fields, VAT tagging for single and multi-purpose vouchers, and audit reports, so the checklist above becomes a configuration job rather than a rebuild.
- Expiry, balance and VAT tagging fields ready to configure on day one.
- Audit reports and cloud dashboards can help with reconciliation across tills.
- Support resources may be available during setup.
- Product demos are sometimes offered before commitment.
If you’re running a café, pub or restaurant, the Hospitality EPOS Bundle is built for venues juggling vouchers alongside mixed-rate food and drink sales. For shops needing integrated card payments and voucher handling in one place, the Integrated Payments Bundle covers both. Book a free demo and see how quickly your till setup can match what this guide covers.
Sources
CMA, HMRC, Law Commission and ICO guidance, linked above, back every legal and technical point here.
- Unfair contract terms: guidance (CMA)
- Unfair commercial practices: CMA207 (CMA, 2025)
- ICO guidance: storage limitation and retention (ICO)
FAQ
Can a UK retailer set any expiry date on a gift card?
Yes, there’s no fixed statutory expiry period, but the term must be fair and clearly disclosed under the Consumer Rights Act 2015. A very short or hidden expiry period is the kind of term that can be challenged as unfair.
Do I have to show the expiry date before someone buys a gift card?
Yes, expiry counts as material information under CMA guidance, so it needs to appear in your invitation to purchase, not just in terms and conditions found later. Show it on the card, at checkout and on the receipt.
When is VAT due on a gift card sale?
It depends on the voucher type: single-purpose vouchers trigger VAT at the point of sale, while multi-purpose vouchers defer VAT until redemption, under HMRC’s voucher guidance. Your EPOS needs to tag each voucher type correctly to get the timing right.
Do I have to honour gift cards if my business becomes insolvent?
Not automatically. Vouchers are generally treated as unsecured claims in an insolvency according to the Law Commission’s review, so honouring them during administration is usually a commercial decision rather than a legal one.
How long should I keep personal data linked to gift card purchases?
Only for as long as you can justify against a specific purpose, such as VAT records or chargeback evidence, as set out in the ICO’s storage limitation guidance. Beyond that period, the data should be deleted or anonymised.
