The unfair trading practices law: what to fix on your website before July 2027

The short answer: show the fees, label the subscription, make leaving easy

From 1 July 2027, three new rules in the Australian Consumer Law change how a business can present prices and sign-ups to consumers. Any fee charged per transaction, such as a booking or service fee, has to be shown right beside the price every time the price appears. Anything that renews automatically, including memberships, plans and free trials that roll into paid ones, has to be clearly labelled as a subscription before someone signs up, and it has to be easy to cancel. And a new general ban covers conduct that manipulates consumers, or unreasonably distorts the setting they decide in, and causes them harm.

Your website is where most of this shows up: the pricing page, the booking flow, the sign-up form and the cancel button. That makes it a website job as much as a legal one, and there's time to do it properly before the deadline rather than in a rush the week before.

This guide is general information for Australian businesses, not legal advice. The Act leaves several details to regulations, so if subscriptions or booking fees are central to your business, have your adviser check your final wording.

What Parliament passed, and when it starts

The Competition and Consumer Amendment (Unfair Trading Practices) Act 2026 passed both Houses on 2 July 2026 and received Royal Assent on 6 July 2026. Its commencement table is short: the whole of the Act starts on 1 July 2027. Nothing in it applies until then, which gives businesses time to plan the changes.

The Act has three working parts. Part 1 adds a general prohibition on unfair trading practices towards consumers. Part 2 adds a drip pricing rule about transaction based charges. Part 3 adds a set of rules for subscription contracts. Breaches can attract civil penalties under the Australian Consumer Law's penalty framework.

None of this replaces the rules you already have to follow. Today, business.gov.au tells businesses: "If you display or advertise prices, always include the total price." Its example is a $100 concert ticket with a $5 booking fee, where the business must show the total price of $105. The new drip pricing section says it doesn't limit the existing single price rule, so both apply from July 2027.

Prices: put every per-transaction fee beside the price

The new drip pricing rule is section 48A. It applies to goods and services of a kind ordinarily bought for personal, domestic or household use. If you display a base price, meaning an amount that includes the price of the goods or services themselves, you must also display information about any transaction based charge. The Parliamentary Library's Bills Digest describes these as charges calculated by reference to the transaction or the way it's carried out, "such as booking and service fees."

The information has to appear while the base price is displayed, close to it, and in a way the Act calls "legible, prominent and unambiguous." A note to the section adds: "This subsection applies each time a base price is displayed." So the fee has to sit beside the price on your pricing page, your timetable or service list, your booking widget and your checkout, not just at the last step.

Some charges aren't covered. The Act excludes charges the customer can choose whether to pay, card payment surcharges, which are handled under a separate part of the Act, and taxes or levies imposed on the supplier. Optional extras are still subject to the general rules about misleading prices, so describe them accurately. Next to each base price you display, you'll need to show:

• The amount of the charge, or if it can't be calculated in advance, how it's calculated.
• That it's a per-transaction charge.
• Whether it is, or may be, payable.
• Whether the price shown already includes it.

Keep readingMake sure the page behind an ad shows the same price

Memberships and plans: label the subscription and make leaving easy

The Act's definition of a subscription contract is wider than streaming services. It covers contracts that supply something on an ongoing basis for an indefinite period with automatic payments, fixed-term contracts that keep running unless someone stops them, free trials that turn into paid supply, and introductory discounts that step up to a higher rate. Gym and studio memberships, maintenance plans, software plans, subscription boxes and ongoing service agreements can all fit. Leases, hire-purchase, payment by instalments, childcare and school tuition are excluded.

When you offer one, you must say that the contract would be a subscription contract, along with information about what the customer will pay, how long it runs, how it renews, any notice needed to end it and how to end it. In writing, that information has to be legible, prominent and unambiguous, close to where the person agrees. If you sell over the phone, it has to be said clearly within a reasonable time before they agree.

Once a subscription is running, you must give subscribers prescribed information at prescribed times. The Act leaves the detail to regulations, and the Bills Digest gives examples such as before a free trial expires, when a subscription renews or when prices change. Every way you offer to end the contract must be easy to find and straightforward, needing only steps that are reasonably necessary. If people can sign up online, one of the ways to cancel must be online.

These ongoing information and cancellation rules protect consumers and small business subscribers: businesses on a standard form contract with fewer than 100 employees or turnover under $10 million. They apply to subscriptions entered into from 1 July 2027. An older contract comes under them when it's renewed, extended, otherwise continued or varied after that date.

Keep readingSee how the same small business test works in agency contracts

Design that pressures or obstructs people

The broadest change is section 28B. A business must not engage in conduct, in connection with supplying goods or services to a consumer, that manipulates the consumer or unreasonably distorts the environment in which they decide, and that causes or is likely to cause them detriment, "whether financial or otherwise." The Bills Digest notes that detriment isn't limited to money and may include wasted time or frustration.

The Act gives examples of conduct that may be unfair, listed at the end of this section. The Explanatory Memorandum, quoted in the Bills Digest, says the prohibition is "not intended to capture legitimate, reasonable or generally accepted marketing or sales practices." A clear offer, a real deadline and a confident call to action are still fine. The Bills Digest says the Act explicitly targets conduct through interface design, defaults and choice architecture. Think of a countdown that restarts every visit, an extra pre-selected at checkout, a cancel link buried three menus deep or a refund process that keeps sending people in circles.

This prohibition protects consumers only. It doesn't apply where the customer is a company or is buying in the course of running a business. When it introduced the Bill, the Government said it had "already commenced targeted consultations on extending protection from unfair trading practices to small businesses and franchisees," so watch for further change. The Act's examples of conduct that may be unfair trading practices are:

• Impeding the consumer's ability to exercise legal rights or seek legal remedies.
• Failing to disclose material information to the consumer.
• Disclosing material information in a complex, ineffective, unclear, unintelligible, ambiguous, untimely or overwhelming way.
• Creating an environment, including through design elements in digital interfaces, that puts the consumer under unreasonable pressure or obstructs them from making or carrying out their decision.

Keep readingHelp visitors decide with clear information instead of pressure

Worked example: a pilates studio's website

This is a made-up example, not a client story. A pilates studio in Bendigo takes every booking through its website. Its timetable says classes are $28, and a $2.50 online booking fee appears only on the payment screen. Its homepage offer reads "First month $49" beside a countdown timer that restarts on every visit, and new members are then charged $45 a week until they cancel. Members sign up online, but the only way to cancel is to email the studio and wait for a call back.

Under today's rules, the studio should already be showing the total price for a booking. From July 2027, each place the $28 price appears also needs the per-transaction fee details beside it. The intro offer is an initial discount period that rolls into ongoing weekly payments, so it's a subscription contract and needs to be labelled as one. Because people sign up online, they also need an online way to cancel. The resetting timer gives a false impression of urgency, and it's the kind of interface design the new general ban is aimed at.

The studio's fix list for its website:

• Show "$28 per class + $2.50 online booking fee per booking ($30.50 total)" on the timetable, class pages and checkout.
• Label the intro offer as a subscription, with the weekly price after the first month, the notice needed and how to cancel, right beside the sign-up button.
• Add a cancel button inside the member account, and keep email cancellation as a second option.
• Replace the resetting timer with the real date the offer ends, or remove it.
• Check what the renewal and price-change emails say once the regulations are made.

A website check to run before July 2027

Start with an inventory of every place a price, a sign-up or a cancel option appears, including booking widgets and payment pages run by third-party software. Your booking or membership platform shapes what customers see, so ask your providers how they'll support fee display, subscription labels and online cancellation before the deadline.

If you're planning a new site or a redesign, with Demandify or anyone else, put these checks in the brief so they're built in rather than patched later. Work through the steps below:

• List every page, ad and checkout step that shows a price, and every fee that's added per booking or per order.
• Make sure each displayed price also shows the total today, and plan to show the per-transaction fee details beside it from July 2027.
• Identify anything that renews, rolls over or steps up in price, including free trials and intro offers.
• Add the subscription statement and its key terms beside each sign-up point.
• Give subscribers an easy, straightforward way to cancel, and an online one if they can sign up online.
• Remove false urgency, pre-selected extras and cancel or refund paths with needless steps.
• Ask your booking, payment and membership providers what they'll change, and when.
• Check the final regulations when they're made, and diarise a review in June 2027.

Keep readingReview how each service page explains your pricing