- Live from
- 1 July 2027
- Instrument
- Competition and Consumer Amendment (Unfair Trading Practices) Act 2026 (Cth), amending the Australian Consumer Law
- Who it captures
- Suppliers of consumer-facing goods or services, regardless of turnover. Small business subscriptions are also captured where the subscriber employs fewer than 100 people or turns over under $10 million on a standard-form contract.
- Penalty
- The greater of $100 million, three times the benefit obtained, or 30% of adjusted turnover during the breach period.
Every one of these has a due date. Missing one is not a judgement call — it is a diary problem.
- Per subscriber (regs pending)Notice before a trial converts
- Per subscriber (regs pending)Notice before renewal
- Promptly, on requestCancellation must complete
- On every changeInterface version captured
What has to happen, repeatedly
- Do not manipulate or unreasonably distort a customer’s decision-making: no false urgency, confirm-shaming or obscured cancellation
- Display transaction-based charges prominently and close to the base price
- Give prescribed subscription term, renewal, pricing and cancellation information before entry
- Send notices at prescribed points before renewal and before a trial converts (detailed timings still being set by regulation)
- Maintain a straightforward cancellation method, online where sign-up was online
What you would have to produce
- The exact interface version each customer saw, with timestamps
- Consent records tied to the offer version displayed
- Every notice sent, when, and whether it was delivered
- Cancellation requests, the route taken, and when billing actually stopped
- Periodic tests of the enrolment-to-cancellation journey
Start with these, and they’re free
- Walk your own sign-up and cancellation flows and time them. If cancelling takes longer, that is the finding
- Turn on your payment platform’s cancellation and refund logging if it is not already recording
- Screenshot the current checkout today. Evidence cannot be created retrospectively
This is general information about an obligation, not legal advice. Whether it applies to your firm, and how, is a question for your lawyer or your professional body.
Last reviewed 2026-09-09