Drip Pricing and Online Cancellation in Australia from 1 July 2027: What a Custom Checkout Has to Change

From 1 July 2027, a business that shows a price for consumer goods or services in Australia has to show every mandatory per-transaction fee right next to it, each time that price appears. A subscription that can be taken out online has to be cancellable online. Both duties come from the Competition and Consumer Amendment (Unfair Trading Practices) Act 2026, which also adds a general ban on unfair trading practices, interface design included.

The Act does not ban fees. It bans revealing them late, and it bans making cancellation harder than it needs to be. For a ticketing site that adds a booking fee at the payment step, or a gym that asks members to phone to cancel, complying means changing code.

If your subscriptions run on Stripe Billing or a similar hosted product, or your shop on Shopify, much of this is configuration in your vendor's product rather than new code. Treasury's impact analysis assumes as much: these platforms "typically allow businesses to integrate easy cancellation processes into their websites and to send notifications to consumers at little to no additional cost". Your part is checking what the vendor changes and when, and reviewing the fees you add on top.

This article is for businesses whose prices, fees and billing come from software they own: an in-house booking engine, a ticketing platform, a native app, a subscription billing system nobody sells an update for. Treasury's Decision Regulation Impact Statement of December 2025 puts it plainly: "Websites and apps will also need to be updated to incorporate simplified cancellation procedures." We are engineers, not lawyers. What follows is what the Act says and what it means for software; whether a particular fee or contract is caught is a question for your legal adviser.

The Dates

The Act is No. 64 of 2026. It received assent on 6 July 2026, and its commencement table has a single row: "The whole of this Act | 1 July 2027". There is no phase-in and no later date for smaller businesses.

The row for existing subscriptions comes from the new section 312 of the Australian Consumer Law: if a contract "is renewed, extended or otherwise continued on or after that commencement", the rules apply "on and from the day on which the renewal, extension or other continuation takes effect". For planning, assume a monthly plan is caught at its first renewal after 1 July 2027, which brings the whole subscriber base into scope within a month. Your adviser can tell you whether that reading holds for your contracts.

The regulator has the date in view. On 3 September 2026, ACCC Chair Gina Cass-Gottlieb said: "From 1 July 2027, the new general prohibition will apply to conduct that manipulates consumers or unreasonably distorts the environment in which they make decisions, and causes harm." The ACCC's priorities for 2026/27 already name "subscription traps and other dark patterns". As of 16 October 2026 we found no ACCC guidance specific to the new sections.

Who Is in Scope

Fee display applies to "goods or services of a kind ordinarily acquired for personal, domestic or household use or consumption". The test is the kind of product, not who buys it. The exemption is an offer "made exclusively to a body corporate", so a trade price list behind a business login is likely out and a public booking page is in.

The subscription rules cover four patterns (s 48B): a rolling contract with no end date, a fixed term that renews unless stopped, a free trial that turns into a paid plan, and an introductory price that steps up. Leases, licences of real property, hire-purchase, payment in instalments, childcare and school tuition are excluded (s 48C). The exit duty protects consumers and also small businesses: a standard form contract with a subscriber that employs fewer than 100 people or turned over less than A$10,000,000 in its last income year (s 48G). A self-serve SaaS plan sold to small companies is in scope too.

The general ban in section 28B protects consumers only: not a body corporate, and not a purchase made in the course of carrying on a business.

Businesses outside Australia are not automatically out. Section 5 of the Competition and Consumer Act extends the Australian Consumer Law to conduct outside Australia by companies incorporated or carrying on business in Australia. Whether you are carrying on business there is a question for a lawyer.

Out of scope for fee display (s 48A(8)): charges the purchaser opts into, card payment surcharges (which have their own rules under Part IVC of the Act), taxes and levies imposed on the supplier, and certain government charges a supplier pays on the purchaser's behalf. Regulations may exclude more; none had been made as of 16 October 2026.

Treasury counts 326,737 businesses taking online orders as affected by the fee rule, and estimates that "approximately 10 per cent of businesses will incur adjustment costs from having to change their online pricing displays", mainly IT costs. It counts 30,600 businesses offering subscriptions.

What a Booking Engine or Checkout Has to Change

A transaction based charge is any charge that "is or may be payable by the purchaser", is not an amount for the goods or services themselves, and is payable at the same time as that amount (s 48A(7)). Booking, service and handling fees fit the wording, and so does a delivery charge the customer cannot avoid: unlike the existing single price rule, section 48A has no delivery exception.

Whenever you display a base price, section 48A(2) requires four things about each such charge: its amount (or, if it cannot be calculated yet, the method for calculating it), that it is a per transaction charge, whether it is or may be payable, and whether the base price includes it. Section 48A(3) sets the manner: "while the base price is displayed", "in a legible, prominent and unambiguous way" and "in close proximity to the base price". A note closes the obvious gap: "This subsection applies each time a base price is displayed."

The ACCC has pursued this under the existing law. In 2015 it accepted undertakings from Airbnb over mandatory service and cleaning fees it considered were not adequately disclosed on search results and listing pages. Section 48A makes that a specific duty on every page that shows a price.

For a custom system, this is what usually needs work:

• Every surface that renders a price. Search results, listing grids, event and product pages, seat maps, the cart and the native app. Check the emails and feeds your system generates as well.
• Fees as a service, not a line added at payment. Many engines compute fees only when the order is built. To show a fee beside every price, the fee rules have to be callable wherever a price is rendered, with the same inputs: product, quantity, channel, delivery method.
• Fees you cannot calculate yet. Before the customer picks a quantity or a delivery option, show the method: a fixed amount per order, or a percentage of the ticket price. The Act allows that. It does not allow silence.
• Channel-specific fees. A fee charged online but not at the box office still belongs beside the online price, with whether it is or may be payable.
• Layout. The Act does not define "close proximity". Until the ACCC publishes guidance, design for the strict reading: the fee in the same visual block as the price, in the same viewport on a phone, and not behind a tooltip or a footnote.
• Optional extras. They are outside section 48A, but the existing single price rule in section 48 still counts a preselected optional charge in the total until the customer deselects it. Leave add-ons unticked.
• The single price stays. Section 48A "does not limit section 48". Where a total can be quantified, the single figure is still required, at least as prominent as any part of the price.
• Tests. A visual regression test per surface and breakpoint that fails when the fee text moves away from the price. Fee display tends to break in the next redesign, not at launch.

What Subscription Billing Has to Change

• Disclosure at sign-up (s 48D). A statement that the contract would be a subscription contract, plus what the subscriber will pay, the period, how it renews, any notice needed to end it and how to end it. Online, it goes "in close proximity to where a person (other than the supplier) can agree to enter the contract": next to the subscribe button, generated from the plan's own data so the text cannot drift from the price.
• An exit that is easy (s 48F). Every way to cancel must be "easy to find" and "straightforward", and require only the steps "reasonably necessary to end the contract and protect the subscriber's interests". Where the subscriber joined online, or you offer online sign-up for that kind of plan, you must "ensure that one of the ways the supplier provides for the subscriber to end the contract is online".
• A cancel flow that actually ends the contract. A link in the account area that leads to a confirmation, not a form that opens a support ticket. Billing has to receive the cancellation as an event, stop the next charge, apply any notice period in the terms and send a confirmation.
• Subscribers without an account. Guest checkout or partner channel subscribers still need an online way out, such as a signed link sent to the email address on file.
• Retention steps. A save offer is not obviously a step "reasonably necessary" to end the contract. If you keep one, make it a single screen that can be declined, and ask your adviser about it.
• Small business subscribers. Your system probably does not store headcount or turnover, so giving every subscriber the same online exit is simpler than working out who qualifies.
• Reminders (s 48E). This duty applies only to contracts and information that regulations prescribe. Treasury expects "automated notification systems to alert consumers before renewals or trial expirations", so build the notification hook now and leave the content to configuration.

Interface Design and the General Ban

Section 28B prohibits conduct that manipulates a consumer, or unreasonably distorts the environment in which they decide, and causes or is likely to cause them detriment. Its examples include disclosing material information "in a complex, ineffective, unclear, unintelligible, ambiguous, untimely or overwhelming way" and "creating an environment (including by using design elements in digital interfaces) which places the consumer under unreasonable pressure in relation to, or obstructs the consumer from, making or fulfilling the consumer's decision".

The Act gives no list of banned patterns; the courts will draw the line. Review first what a product team can find in an afternoon: countdown timers that restart on reload, scarcity messages not tied to real stock, cancel flows longer than the sign-up, a "no thanks" link worded to shame, and defaults that cost the customer money.

The Penalties

The general ban gets the same maximum as the existing unfair practices provisions, and sections 48A to 48F sit in Part 3-1 of the Australian Consumer Law, which is already in the top tier. Under section 224(3A), in the current compilation of the Competition and Consumer Act, the maximum for a company for each contravention is the greater of:

• A$100,000,000;
• three times the value of the benefit reasonably attributable to the contravention, if the court can determine it;
• if it cannot, 30% of the company's adjusted turnover during the breach turnover period.

For an individual the maximum is A$2,500,000. The ACCC can also issue infringement notices for these provisions.

A Plan to 1 July 2027

As of 16 October 2026 there are eight and a half months left. For a custom system that is enough, if the inventory starts now.

1. October to November 2026: inventory. Every surface that renders a price, every fee rule and where it is computed, every subscription plan, sign-up channel and way to cancel.
2. November to December 2026: classify. Sort each charge into base price, transaction based charge, optional extra, payment surcharge, or tax or levy imposed on you. Send the borderline ones to your legal adviser now, not in June.
3. January to March 2027: build. A fee service every price surface can call, fee display on each of them, disclosure generated from plan data, the online cancel flow, cancellation events in billing, and a notification hook.
4. March to April 2027: design review. Walk every purchase and cancellation path against section 28B: timers, defaults, wording, and how many steps leaving takes compared with joining.
5. April to May 2027: test. Visual regression per surface and breakpoint, and end-to-end cancellation for every plan and sign-up channel, guest subscribers included.
6. May to June 2027: release early. Nothing stops you complying before the date, and a June release leaves time to fix what testing missed.
7. From 1 July 2027: watch renewals. Existing contracts come under the rules as they renew. Keep versioned screenshots of what each surface showed and when: that is your record if a question ever comes.

What Could Still Move

The Act leaves details to regulations: reminders (s 48E), further excluded charges (s 48A(8)(e)) and contracts (s 48C), the manner of disclosure in particular cases (s 48D(3)) and exceptions to the exit duty (s 48F(3)). None had been registered on the Federal Register of Legislation as of 16 October 2026.

Treasury also ran a consultation on unfair trading practices protections for small businesses from 3 June to 10 July 2026, which could widen who the general ban protects. The subscription rules must be reviewed after their first two years.

None of this moves 1 July 2027. Keep the fee rules and the disclosure text in configuration, so a regulation changes data rather than code.

Where to Get Help

We change code that businesses already run: price rendering across web and app, fee calculation, subscription billing and cancellation flows, with tests that keep the fee next to the price after the next redesign. Our legacy system maintenance service is where that work usually starts, and if the checkout also needs an accessibility pass, the same audit of every surface feeds into web accessibility remediation.

If your booking engine, app or billing system was built in-house and adds fees at checkout or asks subscribers to call to cancel, write to office@c9group.dev. We are engineers rather than lawyers: which of your charges and contracts are caught is a question for your legal adviser, and we build to the answer they give.