Pricing and promotions
Price comparisons and savings claims
An evidence-led review for was/now, percentage-off, reference-price, RRP and other savings claims.
The comparison conveyed to customers must be genuine.
A savings claim is assessed by the overall impression it creates. Labels such as 'was/now', 'save', 'down down', 'RRP' or a crossed-out price can communicate a specific factual comparison even when no explanatory sentence is used.
In May 2026, the Federal Court found that Coles made false or misleading representations in 13 of 14 sample 'Down Down' tickets. The ACCC alleged that 245 products had been temporarily increased by at least 15 per cent before being placed into the promotion. In June 2026, JB Hi-Fi agreed to refund affected consumers after alleged misleading 'was/now' pricing. These matters reinforce the need for product-level evidence before publication.
Build a claim file for the exact product and period.
- Record the SKU, variant, channel, geography, campaign dates and exact artwork.
- Preserve price history, actual sales volumes and the period used as the comparison.
- For RRP or competitor comparisons, verify the source, currency, market, product identity and how current it is.
- Avoid treating a short-lived, rarely charged or artificial price as the ordinary reference price.
- Set an expiry or recheck date so a claim does not outlive its evidence.
Check every place the price appears.
A defensible claim can become misleading if the product page, search tile, cart, discount code, loyalty offer or checkout uses a different comparison or hides a condition.
- Review headline and qualification together at ordinary screen sizes.
- Confirm the same price and conditions flow through feeds, marketplaces and affiliates.
- Test stacked discounts, member pricing, multi-buy offers and exclusions.
- Give customer-service teams the evidence and approved explanation.
Use a repeatable approval control.
Require the campaign owner to state the customer-facing comparison, attach product-level evidence and obtain approval before launch. Spot-check live claims and keep the final evidence with the final creative, not in separate systems that cannot be reconciled later.
Questions to ask
Focus on the decision and the evidence.
- 01
What comparison will the ordinary customer understand?
- 02
Does evidence support that comparison for the represented product and period?
- 03
Do headline, qualification and checkout information align?
Official sources
Check the primary material.
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.
Tell us how this issue affects your organisation and receive a tailored recommendation for the most useful next step.
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.