Promotional codes are a powerful tool for driving sales, rewarding loyalty and measuring the effectiveness of different channels. Combined with a solid email marketing strategy for events, they can multiply their impact. But used badly, they can cannibalise sales that would have happened anyway and erode your event's perceived value. The key is using them strategically.
It's worth remembering what exactly you're discounting. According to the Live Music Yearbook from Spain's Association of Music Promoters, ticket sales revenue in Spain reached €807.2 million in 2025, up 11.24% on 2024, with Madrid, Catalonia and Andalusia accounting for 63.1% of revenue. Every percentage point you give away in codes comes out of that figure.
And there's a part that rarely gets mentioned alongside the tactics: a discount code is also an advertised price, a line on an invoice and a marketing email. All three are regulated.
What types of codes exist, and when should you use each one?
Not all promotional codes are the same. Each type serves a specific purpose.
- Percentage discount: 10%, 15%, 20%... easy to understand
- Fixed discount: €5, €10 off, better suited to cheaper tickets
- 2-for-1 or group deals: encourage multiple purchases
- Exclusive access: unlocks tickets not available to the public
- Added gift: doesn't reduce the price but adds value (a drink, merchandise)
The type you choose doesn't just change conversion rates — it changes the paperwork too. This table maps the two together.
| Code type | What it's for | How it affects the price and the invoice |
|---|---|---|
| Percentage discount | Boosting volume during slow periods | Reduces the taxable base if applied at the point of sale (Article 78.Three.2 of Spain's VAT Act, Ley 37/1992) |
| Fixed discount | Low-priced tickets, where a % discount loses impact | Same as above; must appear on the invoice if not included in the unit price |
| 2-for-1 or group deals | Filling capacity with extra attendees | A conditional sale: the final unit price changes and must be justifiable |
| Exclusive access | Opening up reserved inventory without lowering the price | There's no price reduction, so it isn't advertised as a discount |
| Added gift | Increasing perceived value without touching the price | Spain's Retail Trade Act (Ley 7/1996) classifies this as a "venta con obsequio" (sale with a free gift) under promotional sales activities |
That last row matters more than it looks. A free gift doesn't lower the price, so it doesn't fall under the "previous price" logic, and it's usually the cleanest option when you don't want to touch your public pricing.
What does Spanish law say about advertising a discount?
The framework sits in Spain's Retail Trade Act (Ley 7/1996). Article 18 lists what counts as a sales promotion activity: «las ventas en rebajas, las ventas en oferta o promoción, las ventas de saldos, las ventas en liquidación, las ventas con obsequio y las ofertas de venta directa» (sales at reduced prices, sales on special offer or promotion, clearance sales, liquidation sales, sales with a free gift, and direct sales offers). Article 19 adds an obligation that almost everyone on social media ignores: «En los anuncios de las ventas a las que se refiere el artículo anterior deberá especificarse la duración y, en su caso, las reglas especiales aplicables a las mismas» (advertisements for the sales referred to in the previous article must specify their duration and, where applicable, any special rules that apply to them).
Article 20 has the most teeth. It requires that, «siempre que se oferten artículos con reducción de precio» (whenever goods are offered with a price reduction), there must be a clear statement of «el precio anterior junto con el precio reducido» (the previous price alongside the reduced price), and it defines the previous price as the lowest price applied to identical products in the preceding thirty days. That wording arrived with Royal Decree-Law 24/2021 and has applied since 28 May 2022, transposing Article 6a that Directive (EU) 2019/2161 inserted into Directive 98/6/EC: «Por "precio anterior" se entenderá el precio más reducido aplicado por el comerciante durante un período de tiempo que no podrá ser inferior a los treinta días anteriores» ('previous price' means the lowest price applied by the trader during a period of time not shorter than thirty days before the price reduction).
Where the nuance lies for organisers
Here's our own reading, not the text of the law itself: both Article 20 of the Retail Trade Act and Article 6a of the directive talk about goods and products, whereas a ticket is the provision of a service. Many promoters invoke that distinction to run discounts without referencing a previous price.
What isn't up for debate is the rest of the package. Article 20.1.c) of the consolidated Consumer Protection Act requires that any commercial practice disclose «el precio final completo, incluidos los impuestos, desglosando, en su caso, el importe de los incrementos o descuentos que sean de aplicación» (the full final price, including taxes, breaking down, where applicable, the amount of any surcharges or discounts that apply). And Spain's Unfair Competition Act (Ley 3/1991) treats as misleading, and therefore unfair, any conduct «que contenga información falsa o información que, aun siendo veraz, por su contenido o presentación induzca o pueda inducir a error» (that contains false information, or information that, even if true, is likely to mislead because of its content or presentation) about price, and its Article 7 also penalises withholding information that's necessary to make a decision.
The practical takeaway: advertising "before €50, now €35" when that ticket was never actually sold at €50 doesn't need Article 20 of the Retail Trade Act to be a problem. Article 5 of the Unfair Competition Act already covers it.
Where the discount ends and pricing begins
A pricing tier isn't a price reduction. If you launch an early-bird rate and close it off by date or by allocation, you're selling different tiers of the same inventory, not discounting something that used to cost more. If instead you lower the current public price and communicate it as a drop, you're advertising a reduction. It's worth having that distinction written into your terms of sale before the campaign, not after a complaint comes in; the same applies if you combine codes with dynamic pricing.
How should you distribute promotional codes?
How and to whom you distribute codes determines how effective they are.
- Influencers: a personalised code to measure real conversions
- Sponsors: a capped allocation for their employees or clients
- Media outlets: an exclusive code for their audience
- Retargeting: a code for abandoned carts or cold leads
- Loyalty: reward repeat buyers
Can you send the code by email?
Only with consent or a prior relationship. Article 21 of Spain's Information Society Services Act (Ley 34/2002) is explicit: «Queda prohibido el envío de comunicaciones publicitarias o promocionales por correo electrónico u otro medio de comunicación electrónica equivalente que previamente no hubieran sido solicitadas o expresamente autorizadas por los destinatarios de las mismas» (sending advertising or promotional communications by email or any equivalent electronic means that have not previously been requested or expressly authorised by the recipients is prohibited).
The exception is a prior contractual relationship: you can write to someone who's already bought from you, provided you obtained their data lawfully and the promotion relates to products or services similar to what they purchased. Every message must offer a simple, free way to opt out, and by email that must be a valid address or equivalent electronic channel.
Two practical consequences follow: your festival's buyer list can be used to promote your festival, not a third party's course; and a code sent to a purchased database isn't a promotion — it's a breach waiting to be reported.
What limits and controls should you set?
Without limits, codes can become a problem. Set clear restrictions.
- Maximum uses: how many times the code can be used in total
- Uses per person: prevents one person using it multiple times
- Expiry date: creates urgency and controls the time window
- Applicable products: only certain tickets or the whole catalogue
- Minimum purchase: applies only if you spend X or more
The expiry date isn't just a lever for urgency: Article 19 of the Retail Trade Act requires promotional adverts to specify their duration and any special rules. A code valid "while stocks last", with no published allocation or date, is exactly what that provision asks you not to do.
There's also one control worth adding that rarely makes these lists: record-keeping. For every code, log who authorised it, which segment it went to, what allocation it had and when it closed. If a discount is ever disputed, the burden of justifying it is yours: the Tax Agency accepts any form of evidence, but it does require evidence.
How is the discount reflected on the invoice and in VAT terms?
It depends on one detail: when the discount is granted. The Spanish Tax Agency's VAT Practical Manual excludes from the taxable base «los descuentos y bonificaciones concedidos previa o simultáneamente al momento en que la operación se realice y en función de ella y que se justifiquen por cualquier medio de prueba admitido en derecho» (discounts and rebates granted prior to or simultaneously with the transaction, in connection with it, and evidenced by any legally admissible means of proof). In plain terms: a code applied at checkout reduces the taxable base; a credit issued afterwards doesn't, and the manual also warns that the exclusion doesn't apply when the reduction is really consideration for a different transaction.
On the invoice, the discount has its own place. Article 6.1 of Royal Decree 1619/2012, Spain's Invoicing Regulation, requires the invoice to state «el precio unitario sin Impuesto de dichas operaciones, así como cualquier descuento o rebaja que no esté incluido en dicho precio unitario» (the unit price excluding tax for those transactions, together with any discount or rebate not already included in that unit price). In other words: if the code isn't baked into the unit price, it has to be itemised.
If the discount arrives late — compensation for a date change, a partial refund agreed afterwards — the route is a corrective invoice under Article 15 of the same regulation, which must be issued as soon as the circumstance comes to light and provided no more than four years have passed since the tax point. Correcting is cheaper than arguing.
How do you avoid cannibalising sales?
The risk with discounts is that someone who would have paid full price ends up using a code. Minimise that risk like this:
- Don't run public discounts: distribute them to specific segments instead
- Unique or limited-use codes: stop them from going viral
- Don't repeat the pattern: if there's always a discount in week X, people come to expect it
- Analyse incrementality: did the code generate new sales, or just shift existing ones? Google Analytics 4 helps you measure this precisely
There's a fourth effect, slower and more expensive: repeated discounting rewrites your audience's reference price. If every edition closes with a 20% discount in the final week, your real price is the discounted one, and the official price is just decoration. The year you can't afford to discount, the drop in sales won't be caused by the price — it will be caused by the expectation you created.
What metrics should you use to evaluate a promotional code?
Measure the real impact of each code to optimise future campaigns.
- Sales per code: how many tickets each code sold
- Net revenue: after the discount, was it profitable?
- Acquisition cost: revenue lost versus the value of the new customer
- Attribution: where each code came from (which channel, influencer, etc.)
To separate new sales from displaced sales, the cheap approach is a control group: hold back an equivalent segment that doesn't receive the code and compare its purchase rate over the same time window. The difference between the two groups is the incremental effect; the rest is discount given away to people who were going to buy anyway. Feed the result into your metrics dashboard with two mandatory columns: gross revenue and revenue after the discount.
Mistakes that cost you
Five common mistakes, all avoidable before you launch the campaign.
Advertising a "before" price that never existed. This falls under Article 5 of the Unfair Competition Act, even though your product is a service rather than a good.
Publishing a promotion with no duration or rules. Article 19 of the Retail Trade Act requires both in the advert.
Sending the code to a list without consent or a prior relationship. Article 21 of the Information Society Services Act doesn't distinguish between a newsletter and a free promo code.
Not itemising the discount on the invoice. Article 6.1 of Royal Decree 1619/2012 requires this when the discount isn't included in the unit price.
Discounting without leaving a trail. Without a record of who authorised what, the discount is impossible to justify to the tax authorities or in your own books.
Conclusion
Promotional codes are a precision tool, not a blunt instrument. Use them with a clear purpose, controlled distribution and rigorous measurement. The goal isn't to hand out discounts — it's to generate sales that wouldn't otherwise happen and build relationships with valuable audiences. To maximise returns, combine them with dynamic pricing and analyse the results on your metrics dashboard.
And before you launch, run through the three layers: what you're advertising (the Retail Trade Act and the TRLGDCU), how you invoice it (the VAT Act and Royal Decree 1619/2012) and who you're sending it to (the Information Society Services Act). A well-designed code holds up against all three without needing a lawyer.
*This article is for informational purposes only and does not replace legal or tax advice. The regulations cited correspond to the linked sources, accessed on 4 October 2026.*
Sources
- Ley 7/1996, Spain's Retail Trade Act, consolidated text (BOE) — Articles 18, 19 and 20.
- Consolidated Consumer Protection Act, Royal Legislative Decree 1/2007 (BOE) — Article 20.1.c).
- Ley 3/1991, Spain's Unfair Competition Act (BOE) — Articles 5 and 7.
- Ley 34/2002, Spain's Information Society and E-Commerce Services Act (BOE) — Article 21.
- Royal Decree 1619/2012, Spain's Invoicing Regulation (BOE) — Articles 6 and 15.
- Ley 37/1992, Spain's VAT Act (BOE) — Article 78.
- VAT Practical Manual 2025, taxable base: general rule (Spanish Tax Agency)
- Directive (EU) 2019/2161, which inserts Article 6a into Directive 98/6/EC (EUR-Lex)
- Live music revenue data for 2025, APM Yearbook (Instituto Autor)
- Google Analytics 4