Australia · Pricing and promotions
Black Friday sales claims under ACCC scrutiny: what retailers should check
Check your discounts, exclusions and urgency claims across websites, emails and social media before your Black Friday campaign goes live.
What the ACCC announced
Black Friday campaigns bring pricing, creative, ecommerce and store operations together under tight deadlines. A compelling offer needs to match what the customer can actually buy, the saving they receive and the time available to act.
On 10 November 2026, the ACCC announced its third Black Friday and Cyber Monday advertising sweep. For the first time, the sweep will examine multiple channels, including websites, emails and social media. Its stated focus includes sale exclusions, misleading time limits, false scarcity, misleading testimonials and reference prices that do not support the advertised saving.
This is an enforcement initiative under the existing Australian Consumer Law. Retailers should use it as a prompt to check both planned promotions and offers already running. Read the ACCC announcement.
Start with the impression your headline creates
A customer may see only an email subject line, a social tile or a banner before deciding to shop. Assess each execution on its own, as well as alongside the terms.
The ACCC’s guidance explains that qualifications must not contradict an advertisement’s overall message. A broad discount claim can be misleading where excluded brands or products appear only in fine print. ACCC guidance on false or misleading claims.
For your campaign review, put the proposed headline beside the actual eligible product list. Ask the buying and ecommerce teams to confirm that the list reflects the offer configured in the system.
If only selected lines qualify, describe those lines in the main message. For example, “30% off selected full-price jackets” gives the creative team a more precise starting point than a broad claim followed by exclusions. It still needs to match the actual offer, pricing evidence and eligibility conditions.
Check member restrictions, discount codes, minimum spends and channel differences at the same time. Put material conditions where customers can see them before acting on the offer.
Check the evidence behind the saving
A percentage discount is only as reliable as the price used to calculate it.
ACCC pricing guidance identifies risks where a claimed previous price was not used for a reasonable period immediately before the sale, or only a very small proportion of items sold at that price. It also warns that a prolonged sale price can become the normal selling price. ACCC guidance on price displays.
We recommend preparing a pricing record for each advertised product or clearly defined product group. Include:
- The comparison price and what it represents.
- Relevant price history, including recent promotional periods.
- Sales volumes at the comparison price and discounted prices.
- The proposed selling price and discount calculation.
- Any differences between online and store pricing.
Keep recommended retail prices clearly distinguished from your own previous selling prices. Escalate comparisons where the basis or supporting evidence is unclear.
For layered offers, test the calculation rather than adding the percentages. A product reduced from $100 to $70, then discounted by a further 20%, costs $56. The combined saving is 44%, not 50%. Make sure the headline, product page and checkout describe the same calculation.
Make the advertised deadline operationally real
The ACCC’s announced focus includes offers that continue beyond their stated end date and inaccurate countdown timers. ACCC Black Friday announcement.
We recommend assigning one person responsibility for the promotion’s start, finish and any proposed extension. Record the applicable time zone and check the settings in the ecommerce platform, email schedule and advertising accounts.
Before launch, test what happens when the timer expires. Does the price change? Does the banner disappear? Does an abandoned-cart message continue promoting the old offer?
Treat a proposed extension as a fresh review point. Consider what earlier advertising told customers, when the decision to extend was made, and whether the same offer was already planned to continue. Updating the terms alone may leave earlier urgency messaging unresolved.
Build a practical withdrawal plan so the team can stop outdated creative quickly across every active channel.
Verify stock messages and testimonials
Claims need a factual basis. The ACCC’s general guidance requires accurate information and substantiation, including for stock availability and testimonials. ACCC guidance on false or misleading claims.
As a practical control, ask whoever manages your website apps to show how urgency messages are generated. Identify whether a low-stock message reflects the particular product, size, colour or location the customer has selected.
Test several products rather than assuming an app works the same way everywhere. Record the settings, the data source and who can change them.
Where testimonials appear in promotional creative, retain the original review and check that editing or shortening it has not changed its meaning. Review automated recommendations and promotional overlays alongside the main artwork.
Follow the offer through to checkout
Advertising approval should include a working purchase test.
Check representative eligible and excluded products on mobile and desktop. Include member and guest journeys, discount codes, sale items, bundles and any minimum-spend thresholds that form part of the offer.
Record what the customer sees at each step: advertisement, landing page, product page, cart and checkout. Confirm that the advertised discount applies as described and that a customer is not surprised by eligibility conditions late in the process.
ACCC pricing guidance also requires clear total pricing, including applicable unavoidable charges that can be quantified. Where charges cannot yet be calculated, the relevant disclosure still needs attention. ACCC business guidance on price displays.
Give customer service and store teams the approved offer summary so they can explain it consistently.
Keep a clear approval record and monitor the live campaign
We recommend a compact campaign file containing final creative, terms, the eligible product list, pricing evidence, test results and approval details. Save dated screenshots of the live customer journey.
Set review points for launch, major stock changes, the planned finish and any extension. Assign an owner for correcting discrepancies and checking that the correction has reached all channels.
If a problem appears, preserve the relevant evidence, stop or correct the affected claim promptly, and assess whether customers have been affected. Seek advice on the response appropriate to the circumstances.
How Watchdog Compliance can help
Watchdog Compliance can review your Black Friday promotional wording, pricing claims, exclusions and terms alongside the supporting evidence and customer journey.
Send us the proposed creative, offer mechanics, relevant pricing records and launch dates. We can help identify gaps and recommend practical changes for your marketing, ecommerce and retail teams.
Contact Watchdog Compliance to arrange a promotion review.
Official sources
Important information
This update is general information for Australian businesses, not legal advice. Laws and official guidance can change. Individual promotions should be assessed against their wording, operation and circumstances.