Loyalty programs must comply with ACL transparency + UCT

Loyalty program T&Cs governed by ACL — UCT regime + misleading conduct.

mediumcurrentongoing

Who must comply

Loyalty program operators + retail brands using them.

What triggers it

Operating a loyalty program with standard form T&Cs.

When due

Continuous.

Evidence required

Reviewed T&Cs against UCT framework; transparency notices; complaints register.

Max penalty

ACL penalties up to $50M / 30% turnover for serious misleading conduct or UCT

Summary

Loyalty programs (Qantas FF, Velocity, Flybuys, etc.) subject to standard form contract regime (UCT regime since November 2023) + s 18 ACL misleading conduct. ACCC inquiry 2019 + ongoing enforcement.

Enforced by

Source legislation

Topics

marketingloyaltyconsumer-law

Source: https://accc.gov.au/business/consumer-rights-and-obligations/consumer-loyalty-schemes. Rules Mate is not a law firm. Always verify against the live regulator source before acting.