Saudi E-Commerce Law Violations: Store Blocking, Fines, Appeals

The owner of an online perfume store wakes up to a message: your store has been blocked. The reason is a customer complaint that the advert said "original perfume" and the product was not. On the other side, a customer paid SAR 1,800 for an order that has not arrived after twenty days, and asks: will my complaint to the Ministry of Commerce get my money back?

The direct answer: violations of the E-Commerce Law are decided by a committee formed by the Minister of Commerce, with at least three members including at least one legal adviser (Article 19). It can issue a warning, a fine of up to SAR 1 million, a suspension of e-commerce activity, or a blocking of the store (Article 18). Anyone against whom a decision is issued may object before the Administrative Court under the Law of Procedure before the Board of Grievances (Article 20). Refunds and compensation are decided by the competent court (Article 22). A complaint to the Ministry opens a violation file, but it is not a refund claim.

Which violations does the e-commerce committee decide?

The law applies to traders registered in the Commercial Register, to unregistered "practitioners" who sell online, and to practitioners outside the Kingdom who offer products in a way that lets consumers in the Kingdom reach them (Articles 1 and 2). The main grounds for liability are:

• Not disclosing the store's name, contact details and register number, if any (Article 6).
• Not giving a statement of contract terms and the total price including fees and delivery, or not issuing an invoice (Articles 7 and 8).
• An online advert with a false or misleading claim, or a trademark the store has no right to use or a counterfeit mark (Article 11); the Ministry may order the advert removed within one day of notice (Article 12).
• Refusing cancellation within seven days of receiving the product, outside the excluded cases (Article 13).
• Delivering more than 15 days after the contract or after the agreed date without force majeure, and refusing a refund (Article 14).
• Using consumer data for unauthorised purposes or disclosing it without consent (Article 5), and a registered trader not recording the online store in the Commercial Register (Article 15).

The committee's jurisdiction rests on Article 19 of the law issued by Royal Decree M/126 of 1440H, which is in force in its published text with no transfer of this jurisdiction.

Urgent blocking of a store: three days and ten days

In urgent and necessary cases, the Minister or his delegate may block the store fully or partly, in coordination with the competent authority, until the violation is fixed or decided. The law limits this with two deadlines: the violation must be referred to the committee within three days of the blocking at most, and the committee must decide within ten days of referral. The committee may lift the blocking fully or partly if it sees a reason (Article 17).

If your store is blocked, count both periods from day one, submit your defence and proof that the violation has been fixed quickly, and ask expressly for the blocking to be lifted.

How does the committee choose the penalty?

The committee may impose one or more of these penalties (Article 18):

• A warning.
• A fine of up to SAR 1 million.
• Temporary or permanent suspension of e-commerce activity.
• Partial or full, temporary or permanent blocking of the online store.

The committee considers the seriousness and repetition of the violation, the size of the store's business and the harm caused to others (Article 19(2)). It may order publication of the decision at the violator's cost once the decision can no longer be challenged or the judgment is final (Article 21). Inspection and recording of violations are carried out by staff appointed by the Minister (Article 23).

How do you object to an e-commerce committee decision?

Article 20 refers objections to the Administrative Court under the Law of Procedure before the Board of Grievances and sets no special period. The general rule in Article 8 of that law therefore applies:

1. File a grievance with the issuing authority within 60 days of learning of the decision; you learn of it when you are notified.
2. The authority must decide within 60 days, and a rejection must give reasons.
3. If the grievance is rejected, or 60 days pass without a decision, file a lawsuit with the Administrative Court within 60 days.
4. If the harm is urgent, such as a blocked store that lives on daily sales, the court may accept an annulment case during the grievance period if it is combined with a request to stay the decision, provided you have filed the grievance with the authority (Article 8(5)).

Filing a lawsuit does not stop the decision automatically; the court may stay it if its enforcement would cause effects that cannot be undone (Article 9). An Administrative Court judgment can be appealed within 30 days of receiving its copy (Article 33). If the notification itself sets a route or period for the grievance, follow whichever is shorter.

What does the committee not handle?

• Getting your money back or compensation for your loss: the competent court decides disputes, including compensation claims arising from the law (Article 22).
• Deliberate fraud, such as a fake store that takes the money and disappears: this is a criminal report, not a commercial violation.
• Warranty for hidden defects in the product: governed by the sale contract rules of the Civil Transactions Law before the court.

A perfume store advertised "100% original", and the products turned out to be counterfeit. The store was blocked on Sunday, and the violation was referred to the committee on Tuesday, the third day.

The committee must decide within ten days of referral. The owner submitted invoices from an approved supplier for part of the stock, withdrew the advert, and asked for the partial lifting of the block for the genuine products.

If a fine is issued, she can file a grievance with the Ministry within 60 days and then an administrative lawsuit. Affected customers claim refunds or compensation from her before the competent court, separately from the committee file.

Practical solutions for both sides

If you are a consumer:

• Ask the store in writing for a return or refund first, citing Article 13 or 14 as the case may be.
• Report to the Ministry of Commerce through its "Balagh Tijari" (commercial report) app, with screenshots of the advert, the invoice and your chats.
• Save the product page as it appeared before the store changes it.
• If you still do not get your money back, file a money claim before the competent court; the outcome of your report strengthens your file.

If you own an online store:

• Disclose your details, contact means and register number on the store, and issue an invoice for every order.
• Review your adverts: words like "original" or "guaranteed" are part of the contract and bind you (Article 10).
• If your store is blocked, count the three-day and ten-day periods and submit proof of correction immediately.
• When a decision is issued, file your grievance within 60 days without waiting, and ask for a stay if the blocking stops your income.
• Settle customer complaints amicably before they reach the Ministry; it costs less than any fine.

If your store was blocked or you received a committee decision, send us the decision and its notification date on WhatsApp and we will review the deadline and the right grievance route with you.

This is general information based on the official Arabic texts of Saudi laws, which prevail over any translation. It is not legal advice for your specific case.