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Loyalty programs must comply with ACL transparency + UCT

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

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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)

Who must comply with this? The applicability test by industry, business structure and size.

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

Related

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://www.accc.gov.au/business. Rules Mate is not a law firm. Always verify against the live regulator source before acting.