About this service
Algorithms now decide which price a consumer sees, which offer appears first on the screen, how many steps it takes to cancel an order and which information stays below the fold. Georgian law has no separate statute for algorithms — the governing framework is consumer-protection legislation: the prohibition of unfair commercial practices and its manifestations, namely misleading commercial practices by action and by omission, and aggressive commercial practices. It is under these norms that a manipulative interface is assessed: where an algorithmic decision pushes a consumer into a transaction they would not have concluded with full information, this is already a legal problem, not merely a design question. This service is intended both for consumers who have become victims of manipulation and for businesses that want their digital services checked for compliance.
The general prohibition of unfair commercial practices
Article 24 of the consumer-protection legislation sets the baseline: unfair commercial practices are prohibited. A commercial practice is unfair where it contradicts the requirements of professional diligence and materially distorts, or is likely to distort, the economic behaviour of the average consumer with regard to the product or service supplied or intended for them. The same rule protects groups of consumers: where a practice is aimed at a defined group, the economic behaviour of the average member of that group must be taken into account, and for particularly vulnerable groups — such as consumers limited by age or abilities — it is precisely the average member of that group whose behaviour is assessed. The law also draws a natural boundary: a practice is not unfair where the information in an advertisement is merely exaggerated or is not meant to be taken literally. Unfair commercial practices comprise misleading commercial practices and aggressive commercial practices — and it is into these two forms that most algorithmic manipulation falls.
Misleading commercial practices by action
Article 25 places under the ban practices that actively mislead the consumer. The law names directly the techniques that are equally at home in a digital environment: offering goods or services at a special price without disclosing the material information on the basis of which the trader expects that it cannot supply the product in the advertised quantity or at the advertised price; promising a special price and then refusing to show the advertised product, to accept an order or to deliver it within a reasonable time; falsely stating that special conditions apply only for a very short period so that the consumer takes an immediate decision and is not given sufficient time and opportunity to make an informed choice; claiming that a product is free when the consumer must in fact pay an additional amount; establishing or promoting a pyramid scheme; inserting into marketing material a payment-obliging document that creates the false impression the consumer has ordered the goods. The general formula is particularly important: a practice is misleading where false information is provided, or information is presented in a manner — even with factually correct content — that deceives or is likely to deceive the average consumer and causes them to take a transactional decision they would not otherwise have taken.
Misleading commercial practices by omission
Article 26 addresses concealment: a trader's commercial practice by omission is misleading where the actual content of the information does not contain the material information the average consumer needs to take an informed decision, or where that information is provided in an unclear, unintelligible or untimely manner. In interface design this covers constructions where the full price, automatically added charges, payment conditions or the right of withdrawal are spread across several screens, hidden in small print or buried in a default setting. The law expressly lists what counts as material information in an offer: the main characteristics of the goods or services; the trader's identity, actual address and identification data; the full price inclusive of main and additional charges — including transport, dispatch and installation — or, where prior calculation of the main price is impossible, the method of its calculation; the conditions of payment, delivery and performance, together with the complaint-handling procedure; and, where applicable, the right to withdraw from the contract. The spatial limitations of a communication medium are no excuse: account must be taken of the trader's efforts to supply the information to the consumer by any other means.
Aggressive commercial practices
Article 27 bans practices that interfere with the consumer's freedom of choice through coercion or harassment. The law names forms that are recognisable in the digital space as well: creating the impression that the consumer cannot leave the trader's premises — or the interface — before concluding a contract; making systematic unsolicited offers by telephone or other means of distance communication; direct exhortations in an advertisement addressed to a child to buy a product or to persuade parents or other adults to buy it; creating the false impression that the consumer has won or will win a prize when no prize exists, or demanding an action that involves paying money in order to claim a supposed benefit. The general test reads: a commercial practice is aggressive where, taking all circumstances into account, through harassment, coercion — including the abuse of influence — it significantly impairs or is likely to impair the average consumer's freedom of choice, and thereby causes the consumer to take a transactional decision they would not otherwise have taken.
What an algorithmic audit covers
The essence of the audit is checking how your digital product operates against the requirements of consumer law. We examine the logic by which offers are displayed, the stages at which price and charges are disclosed, the paths for ordering and cancellation, the weight of default settings, and whether material information is unclear or unintelligible. The result is a concrete list: which constructions create a risk of misleading or aggressive conduct and how they can be fixed. For consumers, the audit's role is played by evidence capture: screenshots of the screens, the history of price changes and the sequence of offers are precisely the material from which a claim is built.
How we can help
Acting for a consumer, we will assess your situation, determine which norm fits which concrete action, and prepare a claim or complaint. For business, we structure a compliance review focused exactly on the points where algorithmic decisions touch the consumer's economic behaviour, and deliver concrete, actionable recommendations. Contact us — at the first meeting you will receive an assessment of whether your case shows the signs of an unfair commercial practice.