Subscription pricing and affiliation claims: checkout review guide

What changed in July 2026

The Federal Court ordered $10 million in penalties after admissions concerning an initial low-price message that obscured an ongoing monthly subscription and misleading government-affiliation claims.

What businesses should do now

Show the ongoing price, billing frequency, minimum commitment and provider identity before payment, and test the full journey rather than relying on later terms or cancellation information.

• Show the amount due now, future amount, billing frequency and minimum commitment before payment.
• Make optional extras genuinely optional and include unavoidable charges in the minimum price.
• Explain trial eligibility, conversion, renewal and cancellation at the decision point.
• Test the journey on mobile, logged-in and guest pathways using real account states.
• Reconcile website promises with billing, refunds, skips, cancellation and confirmation messages.

Evidence to retain

• Versioned offer pages, checkout screens, terms and confirmation messages.
• Customer consent, eligibility and option-selection records.
• Billing events, renewal notices, cancellation logs and refund decisions.
• Journey-test results and records of corrected defects or misleading states.

Turn the issue into a controlled decision

• Record the affected product, claim, customer journey, system, supplier or business process.
• Separate current requirements from proposals, priorities, allegations, warnings and matter-specific outcomes.
• Assign an owner, action date and evidence location for every material gap.
• Set review triggers for legal changes, new facts, supplier changes, incidents, complaints and campaign variations.
• Escalate when the available facts or evidence do not support the proposed decision.

Questions to ask

Focus on the decision and the evidence.

1. 01

   Can a customer understand the minimum price and recurring commitment before payment?

2. 02

   Are optional extras, trials, renewal, cancellation and provider identity presented clearly?

3. 03

   Do billing, confirmation, customer service and cancellation systems honour the published journey?

Primary sources

Check the controlling material.

• Official court decision ↗

Related resources

Continue with this topic.

Recommended training

Practical support

Apply the guidance to your facts.

Identify the exact product, claim, customer journey, supplier, legal entity or 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, official 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.