Australia's new unfair trading laws: is your website customer journey ready for 1 July 2027?
A website can be polished, functional and factually accurate, yet still create an unfair customer experience. Australia's new unfair trading reforms make the fairness of your digital journeys matter more than ever.
- 1 Jul 2027Reforms commence
- 1New general prohibition on unfair trading
- AllBusinesses taking online enquiries or payments
- 3Journey stages to review: before, during, after
In short: From 1 July 2027, Australia's new unfair trading prohibition will increase the importance of fair, transparent customer journeys. Businesses should review how their websites present prices, promotions, optional extras, subscriptions, checkout steps, cancellations, refunds, complaints and support. The aim is not to remove legitimate persuasion - it is to make sure design helps customers understand and act on a genuine choice without unnecessary confusion, pressure or friction.
Key takeaways
The reforms commence 1 July 2027, so there is time to prepare properly.
The whole customer journey matters, not only individual statements on one page.
Dark patterns, hidden fees, subscription traps and hard cancellation deserve particular attention.
Consumer detriment can include wasted time and lost ability to exercise a choice - not just money.
Ethical conversion design can stay persuasive while preserving informed choice.
Review with legal advice where interpretation of the ACL is required.
What is changing under Australia's unfair trading reforms?
The Competition and Consumer Amendment (Unfair Trading Practices) reforms passed the Australian Parliament in 2026 and are scheduled to commence on 1 July 2027. They amend the Australian Consumer Law rather than replace it, and they introduce a new, general prohibition on unfair trading practices, along with targeted measures for subscriptions and for hidden transaction-based charges.
In plain terms, the general prohibition is concerned with conduct that unreasonably manipulates consumers, or unreasonably distorts the environment in which they make transactional decisions, in a way that causes or is likely to cause consumer detriment. The examples on this page are illustrations, not a complete legal test - the precise statutory wording, regulations and regulator guidance may continue to develop before commencement, so confirm the final Act and any ACCC guidance for your situation.
General prohibition
A broad new prohibition on conduct that unreasonably manipulates or distorts how consumers make decisions.
Subscriptions
Targeted measures aimed at unfair subscription practices - sign-up, renewal and cancellation.
Drip pricing
Stronger disclosure of unavoidable transaction-based charges, so the real price is clear early.
Existing law still applies. The new prohibition is additional. Businesses must still consider the rest of the Australian Consumer Law - misleading or deceptive conduct, false or misleading representations, unfair contract terms, unconscionable conduct, pricing rules, consumer guarantees, and rules against harassment or coercion - as well as privacy and spam obligations where relevant.
Commencement date. There is time to review and improve your customer journeys before the reforms take effect - the businesses that start early will have the smoothest path.
Why website design is part of the customer journey
A customer's decision-making environment is partly created by design. Layout, hierarchy, default selections, button prominence and the timing of information all influence which facts a person notices, which option looks recommended, whether a fee is understood, whether declining is easy, and whether cancellation is even visible. On mobile, those effects can be stronger because there is less room to show important information.
This is why design has commercial and ethical consequences, not just visual ones. Good design should reduce cognitive load, make the next step obvious, place important information at the right decision point, and use honest persuasive cues - so customers avoid accidental purchases and feel confident about what they chose.
What are dark patterns?
Dark patterns are interface and journey design techniques that steer, pressure, confuse or obstruct users in ways that can undermine the choices they intended to make.
"Dark pattern" is a design term, not a precise statutory label - so it is not the case that every example is automatically unlawful. What matters is whether the overall design unreasonably interferes with genuine choice or is likely to cause detriment. They matter because they work through layout and interaction rather than explicit false claims, and several small design decisions can combine into a bigger effect. They are often embedded in templates, plugins or third-party checkout tools, so a business owner may not realise their current website relies on them.
| Pattern | What it may look like | Customer impact | Fairer approach |
|---|---|---|---|
| False urgency | A timer that resets or has no genuine deadline | Pressures a rushed decision | Use a timer only for a real, documented deadline |
| Unsupported scarcity | "Only two left" without reliable stock data | Creates fear of missing out | Connect messages to accurate stock information |
| Preselected extras | Insurance, donations or upgrades selected by default | Customers may buy something unintentionally | Leave optional extras unselected |
| Drip pricing | Mandatory charges appear late | Real price cannot be assessed early | Show unavoidable costs at the initial price point |
| Confirm shaming | Decline text insults or embarrasses the user | Applies emotional pressure | Use neutral accept and decline language |
| Visual interference | Preferred choice is bright and large; the alternative is hidden | Makes one option seem unavailable | Give material choices clear, legible treatment |
| Repeated prompting | A declined offer keeps returning | Wastes time and wears down resistance | Respect the previous decision |
| Hidden cancellation | Cancellation is buried behind menus or support | Makes leaving harder than joining | Provide a clear cancellation pathway |
| Forced continuity | A trial rolls into payment without clear reminders | Customers pay without informed awareness | Disclose timing, price and renewal clearly |
| Obstruction | A complaint or refund needs excessive steps | Customers abandon a valid request | Use short, visible, trackable support flows |
| Sneaking | An item is added during checkout | Total changes without clear intent | Require active selection and clear confirmation |
Does persuasive design become illegal?
No. Persuasive design, marketing and conversion optimisation are not automatically prohibited. The question is whether the overall practice unreasonably interferes with genuine choice or is likely to cause detriment.
You can still
- Use clear calls to action
- Highlight genuinely popular products
- Offer relevant upgrades and recommend a suitable plan
- Show real reviews and real stock availability
- Run legitimate promotion deadlines
- Simplify forms and use sensible visual hierarchy
Ask at each decision point
- Is the customer being helped to decide, or is a fact being hidden?
- Is the design exploiting confusion or false information?
- Is declining materially harder than accepting?
- Does the site respect a choice the customer already made?
- Could you explain the design openly to a customer and a regulator?
Review the whole journey, not one page at a time
A single page can look reasonable on its own while the combined journey creates pressure or friction. Review in three stages.
Before purchase
Advertising claims, landing pages, "was/now" pricing, timers, low-stock messages, social proof, pop-ups, disclosures and mobile content order.
Ask: Is the claim supportable and are conditions near it? Is urgency genuine? Can customers compare options fairly, and does mobile hide anything important?During purchase
Cart, optional extras, delivery and service fees, taxes, surcharges, subscription terms, trials, renewals, button labels and the mobile checkout.
Ask: Does the customer see the real commitment? Are mandatory charges disclosed and extras unselected by default? Central to good ecommerce design and retail journeys.After purchase
Order confirmation, subscription management, renewal reminders, cancellation, refunds, returns, complaints, support and account deletion.
Ask: Is leaving as understandable as joining? A retention offer is fine - but risk rises when cancellation is hidden behind it or the process loops.Unsure where your current website creates friction?
Lovely Pixel can review key customer journeys across desktop and mobile, identify confusing or obstructive design patterns, and recommend practical UX, content and development improvements.
Consumer detriment can involve more than a dollar figure
Detriment is not only financial. A journey can create harm even when the amount is small, the customer eventually succeeds, a refund is eventually provided, or the information technically existed somewhere on the site. The design implication is simple: review journeys for time and effort, not only price. We avoid definitive legal conclusions here - likely impact and context both matter - but a process that quietly wastes a customer's time is worth fixing on its own merits.
Website elements to review now
Countdown timers
Check the deadline is genuine and what happens when it hits zero. Avoid timers that restart on refresh.
Fairer practice: Use only for real, documented deadlines; explain what ends and update the offer once it passes.Scarcity & low-stock
Base messages on real inventory, and be clear whether stock is online or all stores. Avoid fake viewer counts.
Fairer practice: Use accurate, current, specific wording and explain scope where needed.Promotional pricing
"Was/now", strikethroughs and RRP comparisons should be supportable, with unavoidable charges disclosed early.
Fairer practice: Keep the basis of comparison clear and qualifications close to the claim; see ACCC pricing guidance.Preselected extras
Insurance, warranties, donations, recurring delivery and marketing consent should not arrive pre-ticked.
Fairer practice: Require an active choice, show recurring impact, and keep service consent separate from marketing.Button hierarchy
Avoid a bright accept paired with a low-contrast or hidden decline, and never rely on colour alone.
Fairer practice: Both choices should be discoverable; labels should describe the outcome with accessible contrast.Pop-ups & prompts
Newsletter pop-ups, wheels and permission requests should respect dismissal and offer an obvious close.
Fairer practice: Use frequency controls, avoid guilt-based decline wording, and test on mobile.Subscriptions
Disclose billing frequency, trial end, first paid date, renewal amount and any minimum term before sign-up.
Fairer practice: Reinforce critical dates and provide a clear online cancellation route where required.Cancellation
Keep it to a short, predictable flow - not buried behind menus, phone calls or business-hours limits.
Fairer practice: Clearly confirm the outcome, send written confirmation, and never let it quietly reopen.Refunds & complaints
Distinguish change-of-mind from consumer-guarantee rights; never bury complaint links.
Fairer practice: Use plain language, clear contact routes and status tracking; match staff processes to the site.Forms & lead-gen
Quote, booking and callback forms should avoid pre-ticked marketing boxes and request only what they need.
Fairer practice: Disclose privacy handling, set clear follow-up expectations, and avoid misleading "free" offers.Mobile design can increase or reduce risk
Smaller screens can push qualifications below the fold, sticky buttons can cover disclosures, modals can become hard to close, comparison tables can lose context, and fees may only appear after several taps. Cancellation menus can be harder to find, and accessibility settings can break layouts. If you are weighing whether patches are enough or a rebuild is warranted, our guide on website redesign covers the trade-offs.
Test every high-value journey on
- Common mobile widths
- Keyboard navigation and screen readers
- High text zoom and slow connections
- Guest and logged-in states
- Validation error states
- Full checkout and cancellation completion
Ethical conversion design is usually better for business
Clearer journeys tend to produce fewer accidental purchases, fewer complaints, fewer refunds, better-qualified enquiries, cleaner analytics and stronger repeat-purchase confidence. Manipulative design can lift a short-term metric while quietly damaging customer lifetime value, review scores, retention, referrals, support costs and regulatory risk.
A practical customer journey self-audit
Offer & advertising
- Are major promotional claims supportable, with qualifications close by?
- Are discount comparisons based on genuine prices, and timers on real deadlines?
- Are scarcity claims connected to reliable data, and testimonials genuine?
- Can mobile users see the same important information?
Product & selection
- Are product differences easy to compare?
- Are recommended options clearly labelled as recommendations?
- Are optional extras unselected by default, and recurring commitments distinguished?
- Can customers go back a step without losing work, with clear button labels?
Pricing & checkout
- Is the total unavoidable cost visible at the right time?
- Are transaction fees disclosed before commitment?
- Can customers review and correct their order?
- Are terms shown before commitment, and does mobile keep context?
Subscriptions & after
- Are billing frequency, trial end and first paid date all prominent?
- Are renewal and price-change terms visible, with reminders where appropriate?
- Are refund, return and complaint pathways easy to find and acknowledged?
- Is cancellation clear, confirmed in writing, and matched by staff processes?
How to run a complete journey review
-
Inventory the journeys
List every path: enquiry, quote, purchase, booking, subscription, registration, cancellation, refund, complaint, warranty, support and account deletion.
-
Identify decision points
Mark where customers choose a product, accept a price, add an extra, agree to recurring payment, provide personal information, confirm, decline or request a remedy.
-
Record what is presented
Capture screenshots, wording, button labels, default settings, total prices, disclosures, pop-ups, emails and confirmation screens at each point.
-
Test realistic scenarios
Desktop and mobile, first-time and returning, guest and logged-in, promotional and standard pricing, successful and failed payment, plus cancellation, refund and complaint flows.
-
Classify findings
Rank by severity, and separately flag anything that needs legal interpretation. Design classifications are not legal conclusions.
-
Prioritise remediation
Hidden or late mandatory fees, unintended subscriptions or add-ons, false urgency, difficult cancellation and obstructed refunds usually come first.
-
Re-test and document
Complete each journey again, verify analytics, check support feedback, close out legal-review items, and schedule a periodic review.
Who should be involved?
A journey review should not sit with one team. Each brings a different lens.
Leadership
Risk appetite, fairness principles, resourcing and approval.
Legal / compliance
Interpretation, industry obligations and formal advice.
Marketing
Claims, promotions, urgency and campaign landing pages.
Ecommerce / product
Defaults, checkout, subscriptions and account controls.
UX & web design
Hierarchy, interaction, accessibility and decision clarity.
Development
Implementation, data accuracy, fee calculation and cancellation logic.
Customer service
The real pain points - complaints, returns and cancellations.
Analytics
Repeated errors, abandonment, circular journeys and mobile failures.
How Lovely Pixel can help
We can review the design, clarity and usability of your website customer journey as a defined engagement within our existing website, UX/UI and redesign work - a Website Customer Journey and Trust Review. That covers navigation and information hierarchy, pricing presentation, calls to action, forms, ecommerce checkout, optional extras, subscription and cancellation interfaces, refund and complaint pathways, mobile usability, accessibility, support discovery, content clarity, trust signals and third-party widgets.
Typical deliverables include a customer journey map, annotated screenshots, an issue register with severity and priority ratings, UX and content recommendations, mobile and accessibility findings, proposed wireframes, an implementation scope, and a clearly separated list of items to refer for legal review, followed by post-change testing.
To be clear about the boundary: Lovely Pixel can review the design, clarity and usability of your website customer journey and identify areas that may require improvement or legal review. We do not provide legal opinions, legal certification or guaranteed compliance. Where legal interpretation is needed, the work should be completed with advice from your solicitor or consumer law adviser.
General information only: This article discusses website design, customer journeys and publicly available information about Australia's unfair trading reforms. It is not legal advice and does not determine whether a particular business practice complies with the Australian Consumer Law. Businesses should obtain advice from a qualified Australian consumer law professional about their specific obligations.
Unfair trading laws and website design
They are scheduled to commence on 1 July 2027, adding a general unfair trading prohibition plus targeted subscription and transaction-fee measures to the Australian Consumer Law.
Not automatically - the concern is false urgency or unsupported scarcity. Genuine deadlines and accurate stock messages are fine; context determines the legal position.
Yes - persuasion and conversion optimisation are not prohibited. The issue is whether the design unreasonably interferes with genuine choice. Ethical conversion design keeps choice informed.
No - it applies broadly, so service, subscription and booking-based businesses should review their journeys too, not only online retailers.
No - a designer can review and improve journey design and flag risks, but cannot certify legal compliance. Legal interpretation needs a qualified consumer law professional.
Make your customer journey clearer before 1 July 2027
A strong customer experience helps people understand your offer, make a genuine choice and complete the action they intended. We review website journeys, forms, ecommerce checkouts, subscriptions and support pathways, then provide practical recommendations for clearer, more trustworthy design.
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