Preparing for Australian unfair trading reforms

The reforms are enacted, with a 1 July 2027 start date.

The Competition and Consumer Amendment (Unfair Trading Practices) Act 2026 received assent on 6 July 2026. It introduces a broad unfair trading prohibition and specific requirements for transaction-based charges and subscription contracts.

Unfair and manipulative practices are the central concern.

The new prohibition is designed to address conduct that unreasonably manipulates or subverts, or is likely to manipulate or subvert, a person's decision or choice and causes, or is likely to cause, material detriment. The practical risk is wider than false statements: design, timing, pressure, friction and the withholding of important information can all affect customer choice.

Unavoidable transaction-based charges need early visibility.

Review fees and charges that arise because of the transaction or payment method. Identify whether the customer can genuinely avoid the charge and whether the displayed price and checkout journey provide the information at the required time.

Subscriptions need clear entry, renewal and exit.

• Explain recurring liability, price, frequency, trial conversion and minimum commitment before agreement.
• Build compliant renewal notices into operational systems.
• Make cancellation practical and do not demand more steps or information than reasonably necessary.
• Plan for existing arrangements that renew, extend, continue or vary after commencement.

Start with the highest-impact journeys.

• Inventory subscriptions, free trials, ticketing and transaction fees.
• Review digital design, pricing, promotions, cancellation and complaints together.
• Update terms, screens, billing, notices, customer-service scripts and evidence records as one change programme.
• Test implementation with real devices and real customer scenarios before 1 July 2027.

Questions to ask

Focus on the decision and the evidence.

1. 01

   Which new requirements apply to each customer journey?

2. 02

   Where does the journey create pressure, asymmetry or friction?

3. 03

   Which systems, terms and controls must change before 1 July 2027?

Official sources

Check the primary material.

• Federal Register of Legislation - Unfair Trading Practices Act 2026 ↗
• ACCC - Advertising and promotions ↗

Practical support

Apply the guidance to your facts.

Identify the exact product, claim, customer journey, supplier, legal entity or business process involved. Preserve the information that supports the current position, record unresolved facts, assign an owner and confirm the point at which specialist review is required.

Important information

Check the current position.

This resource is general information, not legal advice. Laws, regulator guidance and proposals can change. Do not rely on a title or summary alone to decide whether a requirement applies to a particular entity, product or activity.