Loyalty programs must comply with ACL transparency + UCT
Loyalty program T&Cs governed by ACL — UCT regime + misleading conduct.
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 $100M / 30% turnover for serious misleading conduct or UCT (from 28 March 2026)
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
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Frequently asked questions
- Who must comply with Loyalty programs must comply with ACL transparency + UCT?
- Loyalty program operators + retail brands using them.
- What triggers Loyalty programs must comply with ACL transparency + UCT?
- Operating a loyalty program with standard form T&Cs.
- When is Loyalty programs must comply with ACL transparency + UCT due?
- Continuous.
- What is the maximum penalty for Loyalty programs must comply with ACL transparency + UCT?
- ACL penalties up to $100M / 30% turnover for serious misleading conduct or UCT (from 28 March 2026)
- What evidence is required for Loyalty programs must comply with ACL transparency + UCT?
- Reviewed T&Cs against UCT framework; transparency notices; complaints register.
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.