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 go at all.
Some businesses built their whole model on customers forgetting they're subscribed. From 1 July 2027, that gets a lot riskier in Australia.
The Competition and Consumer Amendment (Unfair Trading Practices) Act 2026 received Royal Assent on 6 July 2026. It requires subscription businesses to disclose key terms at sign-up (s 48D), give prescribed notices during the subscription (s 48E) and provide an easy way to cancel (s 48F). It also requires unavoidable transaction fees to be shown with the base price (s 48A) and bans manipulative practices that harm consumers (s 28B).
This checker turns those rules, and the good practice around them, into a readiness score. It reflects the law as at October 2026. It's general information, not legal advice.
How do you use the compliance checker?
- Set your scope. Tick your plan types (ongoing, rolling fixed terms, free trials, intro discounts), who buys, and how they sign up. The checker hides questions that don't apply.
- Answer each check Yes, Partly or No. Only answer Yes when you've seen the evidence: a screenshot, an email, a test transaction.
- Use Partly for anything you're unsure about. Those items become a ready-made list for your lawyer.
- Work the fix list from the top. It puts the riskiest gaps first.
Do the checks on a phone as well as a desktop. Many problems only show up on mobile.
How the readiness score works
Each check carries a weight from 1 to 3. Disclosure at sign-up, the exit and stopping charges after cancellation carry the most. A "No" is a full gap and "Partly" is half.
Readiness % = (1 − Sum of (weight × gap) ÷ Sum of weights) × 100
One check is pushed to the top of the fix list whenever it isn't a clear Yes: does a cancellation always stop the next charge, including before any advertised cut-off? That's not a 2027 problem. In December 2025 the ACCC took HelloFresh and Youfoodz to the Federal Court under today's law, alleging more than 100,000 customers between them were charged after cancelling before the cut-off.
A worked example: an online meal-kit style subscription
The preloaded example sells an ongoing plan with a free trial, online, to consumers. Prices include GST and the online cancel button exists, but key terms sit behind a terms link, the notice period isn't disclosed, there's no trial-end reminder, and leaving takes more clicks than joining.
Result: 49% readiness, not ready yet, with 20 gaps. Notices score just 11% and records 0%. The fix list starts with billing, then disclosure of the notice period, then the click count on the exit.
That's a common picture. Most businesses have the basics of pricing right and very little in place for reminders, because nobody has been required to send them.
What does "ready" look like?
- 85% and above: close to ready. Keep your evidence and re-check when regulations land.
- 60% to 84%: gaps to close. Most can be fixed with copy, settings and a few emails.
- Under 60%: not ready yet. Start this quarter, because billing and checkout changes take time to build and test.
Two things the checker can't settle. First, timing. As at October 2026, the regulations setting when reminders must go out hadn't been published. The February 2026 exposure draft proposed six-monthly reminders for open-ended plans, but that detail moved to regulations. Build reminders with timing you can change. Second, scope. The notice and exit duties also protect small business customers on standard form contracts (fewer than 100 employees or under A$10 million turnover). If you sell only negotiated enterprise contracts, get advice.
What to do next
- Read the full guide to Australia's subscription trap laws, including penalties and who is covered.
- Work through the AU subscription compliance checklist with your team.
- Fix the exit using cancellation rules in Australia, and set up reminders with the automatic renewals guide.
- Planning a price rise? Check raising subscription prices in Australia first.
- Then look at the numbers. Easier cancellation can lift churn for a while, and that flows into cash flow, pricing and value. A BPAG adviser can talk through what recurring revenue could mean for you in a free Subscription Profit Review.
Frequently asked questions
When do Australia's subscription trap laws start?
The Competition and Consumer Amendment (Unfair Trading Practices) Act 2026 commences on 1 July 2027. The subscription rules apply to contracts entered into on or after that date, and to older contracts once they are renewed, extended, continued or varied on or after it. In practice, most businesses should plan as if their whole customer base will be covered.
Do I have to let customers cancel online?
From 1 July 2027, if customers entered the subscription online, or you offer online sign-up, at least one way to cancel must be online. Every way to cancel must be easy to find, straightforward, and require only reasonably necessary steps. A phone line can be one of your ways, but not the only one if people can join online. This is general information, not legal advice.
When do subscription reminders have to be sent?
The Act says suppliers must give prescribed information at prescribed times, with the detail set by regulations. As at October 2026, those regulations weren't published. The Parliamentary Library gives examples such as before a free trial ends, when a subscription renews or when prices change. Build reminders for those moments now, with timing you can adjust.
Can I still make a save offer when someone cancels?
Generally yes, as long as it isn't an obstacle. Keep it to one relevant offer on one screen, such as a pause, a cheaper plan or a discount, with a decline button that's just as visible. Don't require a call or a survey answer before cancelling. Design that puts consumers under unreasonable pressure is one of the examples in the new unfair trading practices ban.
Do the rules apply to business customers?
Partly. The notice and cancellation duties also protect a small business subscriber on a standard form contract if it employs fewer than 100 people or had turnover under A$10 million in its last income year. The general ban on unfair trading practices and the drip pricing rule focus on consumers. If you sell only negotiated enterprise contracts, get specific advice.
Built on The Subscription Playbook
This tool turns frameworks from Robert Coorey's book into something you can use in minutes. Robert is the author of The Subscription Playbook and a Director at BPAG Accountants. More about Robert.