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