Pricing and promotions · Practical campaign guide
Black Friday, red flags: checks you should do before your campaign goes live
Would your Black Friday campaign survive an ACCC sweep? Test the discounts, deadlines, exclusions and ‘early access’ claims before the creative goes live.
Black Friday advertising is under scrutiny
A busy sales event is not a reason to relax the controls.
In April 2026, the ACCC reported that around half of the 50 retailers it reviewed during the previous Black Friday period had made claims that raised concerns. The regulator said it had commenced several investigations.
The concerns included inaccurate countdown timers, ‘sitewide’ or ‘storewide’ promotions with significant exclusions, important conditions in fine print, ‘up to’ discounts that may not have reflected the range, and ‘was/now’ prices that may not have represented genuine savings.
The ACCC's concerns and investigations are not findings that an identified business contravened the law. They do, however, show the claims and campaign mechanics the regulator is examining.
Black Friday claims have already resulted in enforcement action under existing law. In June 2025, Michael Hill, MyHouse and Hairhouse Online each paid an infringement notice penalty of A$19,800 after the ACCC alleged that their Black Friday ‘sitewide’ claims were misleading because exclusions applied.
The practical lesson is that a prominent headline and its real scope need to match.
The execution gap
Campaigns can go wrong between the approved proposition and the live headline.
A carefully qualified offer can become misleading when it is shortened for a banner, email subject line, social post or retailer tile. For example, ‘Early access to selected Black Friday offers at participating retailers’ may be reduced to ‘Black Friday starts now’ even though important limits remain.
Fine print may not correct a broad headline if the overall impression is that the offer is wider, more urgent or more valuable than it really is. The controls need to connect the commercial proposition, price evidence and final creative across every channel.
Seven checks before launch
Make the offer accurate, supportable and consistent wherever customers see it.
1. Approve the proposition before approving the headline
Use one source-of-truth matrix covering the participating SKUs or categories, prices and discounts, prior prices, start and end times, time zones, channels, stock, purchase limits, exclusions, membership or account-linking requirements, and participating brands or retailers.
2. Make the true scope visible
If the offer is limited to selected products, participating retailers, online channels, members, linked accounts or particular brands, put that limitation in or immediately beside the main claim. Do not rely on customers finding it later.
3. Prove every saving
Keep the recent selling history, the duration and volume of sales at the higher price, prior promotional prices and the calculation supporting the claimed saving. If a monetary advantage has not been established, describing the promotion as an ‘offer’ may be safer than making an unsupported savings claim.
4. Treat ‘up to’ as part of the headline
Display ‘up to’ prominently, make sure the maximum discount is genuine and ensure a meaningful number and range of products can achieve it. Check that stock is available when the campaign begins.
5. Make urgency genuine
Countdowns, ‘last chance’, ‘ends tonight’ and similar claims must match the real deadline, including the stated time and time zone. Do not reset a countdown or routinely extend an offer that was presented as ending. Available stock should also support the urgency claim.
6. Make early access genuinely early
Compare like with like: the same product or variant, price, bundle or gift, range, channel and purchase limits. Make any difference prominent and explain what a customer must do to obtain access, such as joining, logging in or using a particular channel.
7. Keep separate offers separate and control every change
A joining reward, membership benefit, trial, gift or product badge should not be blended into the Black Friday offer in a way that misstates value or suggests an endorsement that does not exist. A later change to price, stock, timing, exclusions or creative should trigger another review across the website, email, SMS, app, social, display, retailer content and terms.
The final pre-launch test
Ask three questions before the campaign goes live.
- Can customers understand the offer without hunting through fine print?
- Can the business produce evidence for every discount, deadline and availability claim?
- Does every channel match the final approved proposition matrix?
If the answer to any of these is ‘no’, pause the relevant claim until the gap is fixed.
Official sources
Review the ACCC material and current advertising guidance.
Turn the guide into action
Review the proposition before the creative spreads across every channel.
Watchdog can review the campaign proposition and source-of-truth matrix, price evidence, claim hierarchy, early access or membership conditions, creative and terms, and the controls for later campaign changes.
A focused pre-launch review can identify gaps before the offer appears on websites, emails, social posts and retailer channels.
Important information
Check the live campaign and your specific circumstances.
This update is general information, not legal advice. Advertising claims are assessed in context and laws, guidance and proceedings can change. Check current official material and obtain advice for your circumstances before acting.