A subscription compliance checklist for Australia should cover five areas from 1 July 2027: disclosing that it's a subscription and its key terms before sign-up, showing fees with the base price, sending prescribed notices during the subscription, providing an easy, straightforward exit (online if sign-up is online), and avoiding manipulative design. Add unfair contract terms, billing accuracy and records.
Key takeaways
- The subscription rules in the Unfair Trading Practices Act 2026 start on 1 July 2027 and protect consumers and most small business customers.
- Work through six areas: scope, sign-up, pricing, reminders, cancellation and billing operations.
- As at October 2026, regulations setting reminder timing weren't published, so build reminder timing as a setting you can change.
- Contracts made before July 2027 come under the rules when they're renewed, continued or varied after that date.
- This is general information. Check your own setup with your adviser or lawyer.
In The Subscription Playbook I shared a statistic about gyms that still makes me wince.
About 80 percent of people who sign up for a gym membership cancel within six months. And 50 percent never make it through the doors at all. They subscribe and never go. (If there's a gym card in your wallet you haven't used since March, you know exactly who I mean.)
Some gyms built their whole model on that. It works, I wrote, but it's not the safest subscription model out there.
From 1 July 2027, it gets a lot less safe. Australia's new subscription rules are aimed squarely at businesses whose numbers depend on customers forgetting they're subscribed.
So here's the checklist I'd work through if I ran any subscription business selling to Australians. It reflects the law as at October 2026. It's general information, not legal advice, so check your own setup with your adviser or lawyer. For the background on each rule, read Australia's subscription trap laws.
How to use this checklist
- Copy everything below into a shared doc or spreadsheet.
- Give each section an owner: marketing, product, billing, customer service.
- Tick a box only when you've seen the evidence (a screenshot, an email, a test transaction), not when someone says "I think we do that."
- Anything unticked goes on a fix list with a date. Anything you're unsure about goes on a list for your lawyer.
Do it on desktop and on mobile. Many problems only show up on a phone.
Why bother? Because the maximum company penalty under the Australian Consumer Law is now the greatest of A$100 million, three times the benefit, or 30% of adjusted turnover. More to the point, a clean subscription is one customers trust enough to stay in.
Section 1: Scope (what's covered?)
- I've listed every plan we sell that renews, continues or converts automatically: monthly, annual, free trial, intro discount, add-ons.
- For each plan, I've noted whether it's sold to consumers, small businesses, or larger businesses.
- I've checked which small business customers are protected: standard form contract, and fewer than 100 employees or turnover under A$10 million in their last income year.
- I've checked whether any plan might fall into an exclusion (leases, real property licences, hire purchase, instalment contracts, childcare, school tuition) and asked for advice if so.
- I've listed every channel where people can sign up: website, app, phone, in person, marketplaces.
- I know our renewal dates, and how many existing contracts renew, continue or get varied after 1 July 2027 (that's when older contracts come under the rules).
Section 2: Before sign-up (disclosure)
- The offer clearly states it's a subscription contract.
- It shows what the customer will or may pay, including how often and any price step-up after a trial or intro period.
- It states the contract period (monthly, 12 months, no end date).
- It explains renewal, extension or continuation in plain words ("renews every 12 months until you cancel").
- It states any notice needed to cancel, and any cut-off.
- It explains how to cancel.
- All of this is prominent and close to where the customer agrees, not behind a "terms" link.
- For phone sales, staff say these terms clearly, from a script, before the customer agrees.
- Minimum commitments and early exit fees are in the headline of the offer, not the fine print.
Section 3: Pricing and fees
- Consumer prices show the total price, including GST.
- Any unavoidable per-transaction fee (booking fee, card surcharge, service fee) is shown with the base price, legibly and prominently. If it can't be calculated upfront, the method for calculating it is shown.
- "Free" really means free: if a card is charged at the end of a trial, the price and date are next to the word "free."
- Intro prices show the price that applies afterwards, and when.
- Our pricing page, checkout and confirmation email all show the same numbers.
Section 4: During the subscription (notices)
As at October 2026, the regulations setting the exact content and timing of notices weren't published. Build these now, with timing as a setting you can change.
- Free trials: a reminder before the trial converts, showing the date and the full price.
- Intro discounts: a reminder before the price steps up.
- Annual and fixed-term plans: a reminder before renewal.
- Open-ended plans: a periodic reminder of price and how to cancel (the February 2026 draft proposed every six months).
- Price changes: a notice before the new price applies, listing every option, including any cheaper plan.
- Every notice includes a working cancel link or clear cancel instructions.
- Notices go to an inbox people actually read, and we track delivery.
Ready-to-copy wording: renewal reminder emails, free trial reminders and price increase emails.
Run your sign-up and cancel flow through the checker
The free AU Subscription Compliance Checker asks about your sign-up, reminders and cancellation steps and shows what to fix first.
Section 5: Cancellation (the exit)
- There is at least one way to cancel that is easy to find: a clearly labeled link in account settings, and in billing emails.
- If anyone can sign up online, customers can cancel online.
- Each way to cancel is straightforward, with only steps that are reasonably necessary.
- I've counted the clicks to join and the clicks to leave. Leaving doesn't take noticeably more.
- Any save offer is one offer, on one screen, with an equally visible "No thanks, cancel" button.
- Any exit survey question is optional. (Here's an exit survey you can use.)
- Phone and chat staff process cancellations when asked, and don't make a retention pitch a condition.
- Customers get an immediate confirmation showing the end date and final charge.
- Email cancellation requests are processed, not bounced back.
The cancellation rules guide explains what "easy to find and straightforward" is likely to mean in practice.
Section 6: Design (no manipulation)
- No countdown timers, fake scarcity or pre-ticked add-ons at sign-up.
- No guilt-trip buttons ("No, I don't want to save money").
- No confirm-shaming or loops in the cancel flow.
- Key information isn't buried in long, complex or overwhelming text.
- Someone outside the team has tried the sign-up and cancel flows and described them as fair.
Section 7: Terms and contracts
- Our terms don't let only us decide renewal, or change the price or what's included, without giving customers a penalty-free way out.
- Early termination fees are proportionate, disclosed upfront and explained in one sentence.
- Small business terms have been reviewed for unfair contract terms, which can attract penalties since November 2023.
- Our terms match what our website, sales team and emails actually say.
Section 8: Billing operations
- A cancellation stops the next charge, every time, including before any advertised cut-off.
- Failed-payment retries stop the moment a customer cancels.
- We've test-canceled on every plan and channel this quarter and checked the bank statement.
- Refunds for wrongful charges are automatic, not a fight.
- Billing changes trigger a re-test of cut-offs and cancellations.
That first box is the one the ACCC is already testing. In December 2025 it took HelloFresh and Youfoodz to court, alleging more than 100,000 customers between them were charged after canceling before the advertised cut-off. That's under today's law, not the 2027 rules.
Section 9: Records and people
- We keep dated screenshots of every version of our sign-up and cancel flows.
- We keep copies of every notice and when it was sent to each customer.
- We log cancellation requests and when they were processed.
- Customer-facing staff have been trained, with a written script.
- One named person owns subscription compliance and reviews this checklist every six months.
When this checklist isn't enough
If you sell financial products, energy, telecommunications or health services, sector rules may apply on top of these. Same if you sell mainly through a platform that controls the cancel screens. Get specific advice.
And be honest about the bigger question. If a lot of your revenue comes from people who haven't used your service in months, ticking boxes won't save it. Easy cancellation will expose it. Run the churn risk checklist to see where you're exposed.
What to do next
- Copy the checklist and assign owners this week.
- Run your flow through the free checker below.
- Fix Section 8 first. It's the one that already costs money in court.
- Send your fix list and unsure items to your adviser or lawyer before Q2 2027.
Then look at the numbers. Honest reminders and an easy exit can lift churn for a few months, and that flows into cash flow, pricing and the value of your business.
Free Subscription Profit Review
Australian business owners can book a free 30-minute review with a BPAG Accountants adviser. An honest conversation about:
- whether a subscription model could work for your business
- how recurring revenue could cover your fixed costs each month
- how it could lift what your business is worth
No cost, no obligation. General information only until we understand your situation.
Frequently asked questions
Do these subscription rules apply to sole traders and very small businesses?
The rules apply to the business supplying the subscription, regardless of its size. A sole trader selling a monthly membership has the same disclosure, notice and exit duties as a large company. What changes with size is who you sell to: your consumer customers and small business customers on standard terms are protected, while large businesses on negotiated contracts generally aren't.
Is there an official ACCC checklist for subscriptions?
As at October 2026 I couldn't find an official ACCC checklist for the 2027 subscription rules. The ACCC publishes general guidance on consumer law and unfair contract terms, and regulators often release guidance closer to commencement. Use this checklist as a working document, then compare it with any official guidance and regulations when they're published.
How long does it take to work through this checklist?
For a small business with one or two plans, a focused afternoon gets you through the review, and fixing the gaps may take a few weeks of website, billing and email changes. Larger businesses with several plans, channels and billing systems should allow a few months, because reminder emails and cancellation changes usually need development and testing.
Does the checklist cover GST on subscriptions?
Only at the point of display: consumer prices should show the total amount payable, including GST. Whether GST applies, how you account for prepaid annual plans and how to treat overseas customers are separate tax questions. Those are covered in the guide to GST on subscriptions, and they're worth checking with your accountant.
What if I sell subscriptions through an app store or marketplace?
Platforms such as app stores often control the payment and cancellation screens, which can make some checks hard to tick yourself. You're still responsible for what you say in your own marketing and onboarding. Note which checks the platform handles, keep screenshots of its flow, and get advice on where responsibility sits for your setup.
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Robert Coorey, MBA
Robert is the author of The Subscription Playbook and Feed a Starving Crowd and a Director at BPAG Accountants in Sydney. More about Robert.
Sources
- Competition and Consumer Amendment (Unfair Trading Practices) Act 2026 (No. 64, 2026), Federal Register of Legislation
- Parliamentary Library, Bills Digest No. 58, 2025–26
- ACCC media release, HelloFresh and Youfoodz in court over alleged subscription traps (16 Dec 2025)
- ACCC, Contracts guidance for business (unfair contract terms)
- Assistant Minister for Competition, Government targets hidden fees and subscription traps (9 Feb 2026)
- The Subscription Playbook, Robert Coorey (2022), Chapters 1 and 9
Facts and prices checked 27 October 2026. Spotted something out of date? Tell us.