24/07/2026
Recent amendments to Australian Consumer Law (ACL) recently received Royal Assent and will commence on 1 July 2027. The changes aim to strengthen consumer protections against unfair trading practices.
The central amendments are a principles‑based prohibition on unfair trading practices toward consumers. New Part 2-4 of the ACL will deal with ‘Unfair Trading Practices’ such as misleading and deceptive conduct, unconscionable conduct, and unfair contract terms.
When the changes come into effect, new section 28B will prohibit conduct in connection with the supply or possible supply of goods or services to a consumer that:
- manipulates the consumer, or unreasonably distorts the environment in which the consumer makes, or is likely to make, a decision; and
- causes, or is likely to cause, detriment (whether financial or otherwise) to the consumer.
Examples of conduct that may be captured include:
- conduct that manipulates consumers or distorts the conditions under which transactional decisions are made, including through interface design, defaults, and choice architecture (which are described as ‘dark patterns’).
- Hiding or obscuring important information.
- Creating unreasonable pressure during purchasing decisions.
- Practices that impede consumers from exercising their legal rights.
The changes also strengthen the ACL protections against ‘drip pricing’, which is where additional mandatory fees are added incrementally and revealed late in the purchasing process.
The amendments also introduce specific obligations for subscription contracts, aimed at addressing ‘subscription traps’ that are detrimental to both consumers and small business, including:
- Clear pre-contract disclosures.
- Information on pricing, renewals and cancellation rights.
- Disclosure of renewal, extension or other continuation of the contract.
- Simple cancellation processes.
- An online cancellation option where online sign-up is offered.
What should your business do now to be ready for 1 July 2027:
- Review current business practices and rectify any practices that may in breach of the ACL.
- Review the way you interact with customers to ensure the design and user choices are clear.
- Review your pricing structure and how you show that to customers.
- If you offer subscription contracts, review the terms and conditions to ensure critical information such as pricing, renewals and cancellation is clearly provided.
How can GL help?
Griffin Legal can help our clients review their business practices, consumer interactions and disclosure documents against the upcoming ACL changes. Feel free to contact us if you have any questions or if you are not sure whether you will be impacted by the ACL updates when they commence on 1 July 2027.
