Subscription and auto-renewal compliance

The rules are enacted and begin on 1 July 2027.

The Competition and Consumer Amendment (Unfair Trading Practices) Act 2026 received assent on 6 July 2026. Its subscription contract rules commence on 1 July 2027.

The reforms address automatic renewal or continuation, recurring payment liability and the conversion of a free or discounted trial into a paid arrangement. Existing contracts may also be brought within the rules when they are renewed, extended, continued or varied after commencement.

Make the commitment clear before the customer agrees.

Review the complete sign-up journey, not just the terms document. The price, frequency, trial end, renewal mechanism, minimum term and cancellation method should be prominent when the customer makes the decision.

• State the amount due now and the amount and frequency of later charges.
• Explain when a free or discounted period ends and what happens next.
• Do not rely on a preselected option, faint qualification or information available only after payment.
• Keep a reliable record of the version of the offer and the customer's agreement.

Build reminders and cancellation into the operating process.

The legislation includes renewal-notice and cancellation requirements. Cancellation must not require more steps or information than are reasonably necessary. Test the actual logged-in, mobile and customer-service experience.

• Identify which contracts and renewal events require a notice and when it must be sent.
• Make the notice useful: identify the contract, timing, price and cancellation route.
• Let customers cancel through a practical route without avoidable calls, delays, repeated questions or retention barriers.
• Align billing, customer service, complaints and refund handling with the published journey.

Prepare the system, evidence and transition plan now.

• Inventory subscriptions, memberships, automatic replenishment, free trials and recurring service arrangements.
• Map every screen, email, payment event, renewal and cancellation step.
• Assign owners across legal, digital, billing, customer service and data teams.
• Plan how contracts entered before 1 July 2027 will be handled at the next renewal, extension, continuation or variation.
• Monitor final regulator guidance and test controls before commencement.

Questions to ask

Focus on the decision and the evidence.

1. 01

   Is the ongoing commitment clear before sign-up?

2. 02

   Can customers understand total price, renewal and cancellation?

3. 03

   Do design, defaults and operations match the written terms?

Official sources

Check the primary material.

• Federal Register of Legislation - Unfair Trading Practices Act 2026 ↗
• ACCC - 2026-27 compliance and enforcement priorities ↗

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.