Compliance playbook for retail and e-commerce businesses
Australian Consumer Law (consumer guarantees, misleading conduct s 18/29, country-of-origin labelling, unsolicited consumer agreements, gift card 3-year minimum), product safety (mandatory standards + bans), pricing display (multiple-pricing rule + component pricing), Privacy Act 2026 (ADM transparency from 10 Dec 2026), Spam Act consent + unsubscribe, Do Not Call Register, CDR (if banking / energy), Designs Act + IP, ePayments Code, BNPL ACL from 10 June 2025 if BNPL offered, GST + BAS + low-value imported goods GST under $1,000, allergen labelling for food, country-of-origin labelling — every obligation a retail or e-commerce operator faces.
Key deadlines — next 12 months
- 10 December 2026Privacy Act ADM transparency + Children's Code commence
- 1 July 2026Payday Super starts (per-pay-event SG)
- Within 30 daysNDB assessment of suspected breach
- Within 2 daysMandatory product safety incident report (s 131)
- Within 72 hoursRansomware payment report (Cyber Security Act 2024)
- AnnualModern Slavery Statement (if revenue >$100M)
Does this apply to me?
Answer yes to any of the below and the obligations in this playbook are likely relevant.
- 1Do you sell products or services to consumers in Australia (Australian Consumer Law applies to every sale, regardless of channel)?
- 2Do you sell online — including via your own website, Shopify, marketplace platforms (Amazon, eBay, Kogan), or through social commerce (Instagram, TikTok Shop)?
- 3Do you sell into Australia from offshore (low-value imported goods GST applies for goods under $1,000)?
- 4Do you sell gift cards (3-year minimum expiry rule under ACL Pt 3-2 Div 4)?
- 5Do you offer BNPL, store credit, layby, or other consumer credit (NCCP Act + BNPL reforms from 10 June 2025)?
- 6Do you send marketing electronic messages or make telemarketing calls (Spam Act + Do Not Call Register)?
- 7Is your annual turnover at or above AUD $3M (Privacy Act small business operator threshold)?
Plain English summary
Retail and e-commerce in Australia carry a compliance load that grew sharply between 2023 and 2026. The Australian Consumer Law (ACL) — Schedule 2 to the Competition and Consumer Act 2010 — sets the floor: consumer guarantees, misleading conduct prohibitions (s 18, s 29-34), pricing rules, unfair contract terms, product safety, unsolicited consumer agreements, gift card 3-year minimum (since 1 November 2019), and the unsolicited supply rules. Civil penalties for breaches were raised in November 2022 to the higher of $50M / 3× benefit / 30% turnover.
Online retail layers more obligations on top. The Spam Act 2003 catches commercial electronic messages (email, SMS, push notifications). The Do Not Call Register Act 2006 catches telemarketing. The Privacy Act 1988 applies above $3M turnover (and earlier on carve-in conditions) — and from 10 December 2026, ADM transparency in the APP 1 Privacy Policy + the Children's Online Privacy Code commence. Cross-border data flows (Stripe, AWS, Shopify) trigger APP 8.
Payment-side regulation is dense. The ePayments Code (ASIC) covers electronic payments and the rights of consumers in card disputes. BNPL providers operate under a modified credit licence regime under the NCCP Act + Low Cost Credit Contract rules from 10 June 2025. CDR applies if you operate in the banking / energy / non-bank-lending perimeter or accept CDR-shared consumer data from accredited providers.
This playbook lists every obligation a retail or e-commerce business faces today, the section of the Act it sits under, who is accountable, the cadence, the maximum penalty, and a regulator-direct source. Cross-link to the unfair contract terms checker and the Privacy Act 2026 readiness check.
Obligation checklist
Every obligation cites the Act and section. Source URLs link to the regulator's portal — Rules Mate does not republish statutory text.
- 1
Australian Consumer Law (Sch 2, Competition and Consumer Act 2010), Pt 3-2 Div 1 — consumer guarantees
Every supply of goods or services to a consumer (under $100K or for personal/domestic/household use) must comply with the consumer guarantees: acceptable quality, fit for disclosed purpose, match description/sample, supplied within reasonable time, free of undisclosed encumbrances, due care and skill (services). Major failure entitles refund + damages; minor failure entitles repair/replace.
- Who's responsible
- Operator / Owner + Customer Service
- Frequency
- Continuous; per sale
- Penalty
- Up to $50M / 3× benefit / 30% turnover (corporate) for false-or-misleading conduct around guarantees.
- Source
- Regulator-direct link
- 2
Australian Consumer Law, ss 18 + 29 — misleading or deceptive conduct + false representations
Do not engage in conduct that is misleading or deceptive (or is likely to mislead or deceive) in trade or commerce. Do not make false or misleading representations about goods, services, country of origin, testimonials, sponsorship, price.
- Who's responsible
- Marketing + Operator
- Frequency
- Continuous
- Penalty
- Up to $50M / 3× benefit / 30% turnover (corporate); ACCC enforcement.
- Source
- Regulator-direct link
- 3
Australian Consumer Law, Pt 3-1 Div 1 + Country of Origin Food Labelling Information Standard 2016
Use country-of-origin labels truthfully and consistently with the safe-harbour rules. For Australian-grown / Australian-made / Product of Australia / Made in Australia: meet the substantial-transformation + cost-of-production tests.
- Who's responsible
- Buying / Marketing
- Frequency
- Continuous
- Penalty
- Same ACL penalty regime; ACCC enforcement.
- Source
- Regulator-direct link
- 4
Australian Consumer Law, Pt 3-3 — product safety mandatory standards + bans + recalls
Comply with all mandatory product safety standards (e.g. button batteries, baby walkers, prams, basketball rings, water beads from 1 March 2024). Do not supply banned products. Report serious injury / death within 2 days under s 131. Cooperate with mandatory recalls.
- Who's responsible
- Operator + Buying + Compliance
- Frequency
- Continuous; mandatory reports event-driven
- Penalty
- Up to $50M / 3× benefit / 30% turnover (corporate); criminal offences for serious breaches.
- Source
- Regulator-direct link
- 5
Australian Consumer Law, s 47 — multiple pricing rule
If a product is displayed with more than one price, the seller must charge no more than the lowest price (or withdraw the product from sale). Also: don't advertise a price unless the total price including all unavoidable charges (GST, surcharges) is also displayed (component pricing rule, s 48).
- Who's responsible
- Operator + Store / Web Manager
- Frequency
- Continuous
- Penalty
- Up to $50M / 3× benefit / 30% turnover (corporate); ACCC enforcement.
- Source
- Regulator-direct link
- 6
Australian Consumer Law, Pt 2-3 — unfair contract terms (standard form)
Standard-form consumer and small-business contracts must not contain unfair terms. From 9 November 2023, unfair terms attract civil penalties up to $50M (corporate). Common UCT risks in retail: unilateral variation, automatic renewal, limitation of liability, exclusive remedies, restrictive cancellation.
- Who's responsible
- GC / Operator
- Frequency
- Continuous; review on material change
- Penalty
- Civil penalty up to $50M / 3× benefit / 30% turnover per term.
- Source
- Regulator-direct link
- 7
Australian Consumer Law, Pt 3-2 Div 4 — gift cards (3-year minimum expiry)
Gift cards supplied at retail must be valid for at least 3 years from supply. Display expiry date prominently. Do not charge post-purchase fees that erode value (some exceptions for activation, foreign transaction, etc).
- Who's responsible
- Operator + Marketing
- Frequency
- Continuous
- Penalty
- Civil penalty up to $30,000 (corporate) per breach.
- Source
- Regulator-direct link
- 8
Australian Consumer Law, Pt 3-2 Div 2 — unsolicited consumer agreements
Unsolicited consumer agreements (door-to-door, telemarketing-initiated, party-plan) attract a 10-business-day cooling-off period and explicit disclosure rules. Most pure-online retail is not unsolicited — but outbound telesales, in-mall recruitment, social-DM-initiated sales can be.
- Who's responsible
- Sales + Operator
- Frequency
- Per sale
- Penalty
- Civil penalty + the agreement is unenforceable during cooling-off period.
- Source
- Regulator-direct link
- 9
Spam Act 2003 (Cth), s 16
Do not send commercial electronic messages without consent (express or inferred); include sender identification + a functional unsubscribe in every message. Applies to email, SMS, push notifications, in-app messages with commercial content.
- Who's responsible
- Marketing
- Frequency
- Every campaign
- Penalty
- Up to $2.355M per day for serious breaches; ACMA enforcement.
- Source
- Regulator-direct link
- 10
Do Not Call Register Act 2006 (Cth)
Do not make unsolicited telemarketing calls to numbers on the Do Not Call Register. Wash lists at least every 30 days. Existing-customer relationship exemption is narrow — defaults are unlikely to cover cold outreach.
- Who's responsible
- Sales + Marketing
- Frequency
- Every campaign; register check at least every 30 days
- Penalty
- Up to $2.355M for serious repeated breaches; ACMA enforcement.
- Source
- Regulator-direct link
- 11
Privacy Act 1988 (Cth), Sch 1 — Australian Privacy Principles
If turnover is at or above $3M (or you handle health information, contract to Government, or trade personal information), comply with all 13 APPs. Publish a Privacy Policy (APP 1) covering ADM from 10 December 2026; provide collection notices (APP 5); secure customer data (APP 11); apply APP 8 for offshore disclosure (Stripe, AWS, Shopify).
- Who's responsible
- Privacy Officer + CTO + Marketing
- Frequency
- Continuous
- Penalty
- Up to $50M / 3× benefit / 30% turnover for serious or repeated interferences.
- Source
- Regulator-direct link
- 12
Privacy Act 1988 (Cth), Pt IIIC — Notifiable Data Breach scheme
Notify the OAIC and affected individuals of eligible data breaches likely to result in serious harm. Assessment within 30 days. Retail customer-database breaches (Optus, Medibank, ATO-style) are high-risk.
- Who's responsible
- Privacy Officer + Incident Response Lead
- Frequency
- Event-driven
- Penalty
- Up to $50M / 3× benefit / 30% turnover.
- Source
- Regulator-direct link
- 13
Privacy Act 2026 amendments — ADM transparency + Children's Online Privacy Code from 10 December 2026
From 10 December 2026: where ADM is used to make decisions that significantly affect individuals (price personalisation, credit decisioning, fraud-block decisions), disclose in the APP 1 Privacy Policy. Children's Online Privacy Code applies if you target users under 16.
- Who's responsible
- Privacy Officer + CTO + Marketing
- Frequency
- From 10 December 2026; ongoing
- Penalty
- Same Privacy Act penalty regime; OAIC enforcement.
- Source
- Regulator-direct link
- 14
Competition and Consumer (Industry Codes — Consumer Data Right) Regulations + CDR Rules
If operating in Banking, Energy, or Non-Bank Lending sectors as a data holder or accredited data recipient: comply with CDR Rules + 13 Privacy Safeguards. Most pure retail is out of scope — but retail BNPL providers, cash-back / open-banking apps, and energy retailers are captured.
- Who's responsible
- CTO + Compliance
- Frequency
- Continuous (if applicable)
- Penalty
- Civil penalty up to $50M / 3× benefit / 30% turnover.
- Source
- Regulator-direct link
- 15
ePayments Code (ASIC)
Subscribers to the ePayments Code (most retailers issuing or accepting electronic payments via PCI-DSS providers) must comply with chargeback and unauthorised-transaction provisions. Investigate disputes within stipulated timeframes.
- Who's responsible
- Customer Service + Finance
- Frequency
- Per dispute
- Penalty
- Code is voluntary but breach can be a misleading-conduct contravention; ASIC enforcement.
- Source
- Regulator-direct link
- 16
National Consumer Credit Protection Act 2009 (Cth) — BNPL from 10 June 2025
If you offer Buy Now Pay Later directly (vs. embed Afterpay / Zip / Klarna): from 10 June 2025, operate under the BNPL modified credit licence regime + Low Cost Credit Contract rules. Lite responsible-lending obligations + hardship + dispute resolution + design and distribution.
- Who's responsible
- GC / Operator
- Frequency
- Continuous (if BNPL offered)
- Penalty
- Civil penalty up to $15.65M (individual); $156.5M (corporate); ASIC enforcement.
- Source
- Regulator-direct link
- 17
Designs Act 2003 (Cth) + Trade Marks Act 1995 (Cth) — IP enforcement
Don't infringe registered designs or trade marks. Use TMs for branded products; respect competitor designs. Monitor copy-cat product imports through ABF Notice of Objection scheme.
- Who's responsible
- GC + Buying
- Frequency
- Continuous
- Penalty
- Civil — damages, account of profits, injunctions; criminal under Trade Marks Act for counterfeiting.
- Source
- Regulator-direct link
- 18
A New Tax System (Goods and Services Tax) Act 1999 + Treasury Laws Amendment (GST Low Value Goods) Act 2017
Register for GST when annual turnover is or will be $75,000+. Collect GST on low-value imported goods (under $1,000) sold to Australian consumers if you are a non-resident merchant + GST turnover above $75,000 from Australian sales. Lodge BAS.
- Who's responsible
- Finance / Bookkeeper
- Frequency
- Quarterly (or monthly)
- Penalty
- Failure-to-lodge + General Interest Charge; ATO audit review.
- Source
- Regulator-direct link
- 19
Food Standards Code, Standard 1.2.3 + PEAL labelling — allergens (if selling food)
If selling food (packaged or unpackaged), declare all 10 nominated allergens (gluten, crustacea, egg, fish, milk, peanut, sesame, soy, tree nuts, lupin) per Standard 1.2.3 + Plain English Allergen Labelling rules.
- Who's responsible
- Buying + Compliance
- Frequency
- Continuous; per SKU launch
- Penalty
- Civil penalty under state Food Act; product recall.
- Source
- Regulator-direct link
- 20
Modern Slavery Act 2018 (Cth), s 5 — reporting entity
Where consolidated revenue is AUD $100M or more: lodge an annual Modern Slavery Statement on the Modern Slavery Statements Register within 6 months of the end of the reporting period. Retail global supply chains (apparel, electronics, homewares) are high-risk and require deep diligence.
- Who's responsible
- CFO + Company Secretary
- Frequency
- Annual
- Penalty
- Public listing on register; civil penalties proposed under Modern Slavery Amendment Bill 2024.
- Source
- Regulator-direct link
- 21
Cyber Security Act 2024 (Cth) — ransomware payment reporting
From 30 May 2025: entities with annual turnover above $3M (or critical-infrastructure entities) must report ransomware payments to the Department of Home Affairs within 72 hours of the payment.
- Who's responsible
- CISO + GC
- Frequency
- Event-driven
- Penalty
- Civil penalty (60 penalty units, ~$19,800).
- Source
- Regulator-direct link
Deadlines
Pulled from the Rules Mate compliance calendar. Click through for the full deadline page.
- 10 December 2026
ADM transparency obligation in force
APP entities must disclose significant ADM use in privacy policy.
- 10 December 2026
Children's Online Privacy Code in force
OAIC Children's Code (binding) in force.
- 14 July 2026
STP end-of-year finalisation
Finalise STP submissions for the previous financial year by 14 July.
- 1 July 2026
Payday Super commences
Super contributions must reach the employee's fund within 7 business days of each payday. New STP fields (QE + Super Liability).
- 31 December 2026
Modern Slavery Statement (FY26 ending 30 June)
Within 6 months of FY end — typically 31 December for 30 June year-ends.
Forms and regulator portals
Direct links to the lodgement forms and regulator portals. Rules Mate does not host copies — we link to the official source.
ACCC — product safety reporting + recall portal
Lodge mandatory product safety incident reports (s 131) and recall notifications.
Open portal →ACMA — Spam Act enforcement / complaints
Report a spam breach or seek guidance on Spam Act compliance.
Open portal →Do Not Call Register — washer access
Telemarketers must subscribe to the Register and wash lists at least every 30 days.
Open portal →OAIC — Notifiable Data Breach notification
Report an eligible data breach involving customer information.
Open portal →Modern Slavery Statements Register — lodgement
Lodgement portal for entities at or above the $100M consolidated revenue threshold.
Open portal →ATO — Business Activity Statement portal
Lodge BAS, manage GST, PAYG, fuel tax credits.
Open portal →Australian Border Force — Notice of Objection (counterfeit goods)
Register an IP notice to enable ABF seizure of counterfeit imports.
Open portal →
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What changes 2025–2026
9 November 2023 — Unfair Contract Term civil penalties live
UCT contraventions attract civil penalties up to $50M / 3× benefit / 30% turnover (corporate). Audit standard-form terms (T&Cs, returns policies, subscription terms).
8 February 2024 — Plain English Allergen Labelling
PEAL labelling rules in Standard 1.2.3 became mandatory for food. Affects food retailers and grocers.
1 March 2024 — Water bead mandatory ban
ACCC introduced mandatory ban on supply of water beads + water-bead toys after multiple ingestion injuries.
10 June 2025 — BNPL modified credit licence regime live
BNPL providers operate under NCCP Act + Low Cost Credit Contract rules. Retailers offering direct BNPL are captured; embedded Afterpay/Zip/Klarna shifts the obligation to the provider.
30 May 2025 — Cyber Security Act ransomware reporting
Retailers above $3M turnover must report ransomware payments to Home Affairs within 72 hours.
1 July 2025 — SG to 12%
The Super Guarantee rate stepped up to 12% from 1 July 2025.
1 July 2026 — Payday Super starts
Super Guarantee shifts from quarterly to per-pay-event.
10 December 2026 — Privacy Act ADM transparency + Children's Online Privacy Code
APP 1 Privacy Policy must disclose ADM that significantly affects individuals. Children's Code applies to retail platforms targeting under-16s.
Ongoing — ACL review + ACCC enforcement priorities
ACCC enforcement priorities consistently feature: misleading environmental claims (greenwashing); subscription traps + auto-renewal; product safety; misleading discount claims (was-now pricing); unfair contract terms.
In-depth reading
24 Rules Mate articles tagged to this playbook.
Australian Consumer Law: the consumer guarantees explained
Sections 54-59 of the ACL set out the guarantees that apply to most consumer goods and services in Australia. Here's what each guarantee means and what the remedies are.
ACL misleading or deceptive conduct: sections 18 and 29
Section 18 of the Australian Consumer Law prohibits misleading or deceptive conduct in trade or commerce. Section 29 targets specific false representations about goods and services. Here's how they differ.
Country of Origin labelling in Australia: the Information Standard explained
Most food sold in Australia must carry country-of-origin labelling under the Country of Origin Food Labelling Information Standard 2016, made under the Australian Consumer Law.
Allergen labelling in Australia: Plain English Allergen Labelling (PEAL) explained
Food Standards Code Standard 1.2.3 requires mandatory declaration of 10 prescribed allergens. PEAL took effect 25 February 2024 with a transition period to 25 February 2027.
Spam Act 2003: the three rules every Australian sender must follow
The Spam Act 2003 governs commercial electronic messages sent to or from Australia. Three rules: consent, identification, unsubscribe. Penalties under ACMA enforcement can reach $2.96M per day.
Do Not Call Register: who can call, who can't, and the rules
The Do Not Call Register Act 2006 prohibits unsolicited telemarketing calls and marketing faxes to registered numbers. Here are the rules, the exemptions, and the enforcement.
Privacy Act 2026: what Australian SMBs need to do before 10 December
On 10 December 2026, ADM transparency and the Children's Online Privacy Code commence. The proposed small business exemption removal — which would bring ~2 million SMBs into APP scope — is not yet law. Here's what you need in place.
Privacy Act 2026: 8 questions every Australian SMB should answer
Removing the small business exemption is proposed for a future reform tranche — not yet law — but if enacted ~2 million SMBs would become APP entities. Answer these 8 questions to know where you stand.
APP 8 overseas disclosure: when AU businesses are accountable for what an overseas recipient does
Australian Privacy Principle 8 makes an APP entity accountable for what an overseas recipient does with personal information it discloses. Here's the rule, the exceptions, and how to discharge the obligation.
BNPL Becomes Regulated Credit: ACL Required from 10 June 2025
The Treasury Laws Amendment (Responsible Buy Now Pay Later and Other Measures) Act 2024 brings BNPL contracts into the NCCP Act as 'low cost credit contracts', requiring providers to hold an ACL from 10 June 2025.
ePayments Code 2022: ASIC's Updated Consumer Protections for Electronic Payments
ASIC published the updated ePayments Code on 2 June 2022 (mandatory from 2 June 2023), covering mistaken internet payments, unauthorised transactions, NPP payments and complaints handling.
Consumer Data Right: Banking Data Holder and Accredited Data Recipient Duties
How the Consumer Data Right works in banking, including data holder obligations and the ACCC accreditation process for data recipients.
Cyber Security Act 2024 — mandatory ransomware payment reporting
How Part 3 of the Cyber Security Act 2024 (Cth) requires reporting entities to notify ASD within 72 hours of making or being aware of a ransomware payment.
Notifiable Data Breach: a step-by-step walkthrough for the first 30 days
What to do hour-by-hour when you discover a suspected data breach. The 30-day assessment, the notification triggers, OAIC and affected individuals.
Australian compliance calendar 2026–2027: every deadline you need
A month-by-month list of every major Australian compliance deadline for 2026 and 2027 — tax, super, AML, privacy, climate, WHS, modern slavery. Free .ics download.
Privacy Act vs GDPR: what Australian businesses actually need to know
How Australia's Privacy Act and Australian Privacy Principles compare to the EU's GDPR — thresholds, consent, breach notification, penalties, and what changes for AU businesses in December 2026.
The Notifiable Data Breach 30-day rule explained
Under the Privacy Act's NDB scheme you have up to 30 days to assess a suspected breach, then must notify the OAIC and affected individuals. Here's how both clocks work.
Consumer Data Right (CDR) in Australia: open banking, open energy and what's coming
The Consumer Data Right lets consumers share their banking, energy and (progressively) other data with accredited third parties. Here's the framework, the participants and the Privacy Safeguards.
The Privacy Act statutory tort for serious invasions of privacy
Schedule 2 to the Privacy and Other Legislation Amendment Act 2024 created a new statutory cause of action for serious invasions of privacy. It commenced 10 June 2025. Here's the framework.
The My Health Records Act 2012: access, controls and offences
The My Health Records Act 2012 establishes Australia's My Health Record system. Strict access rules, audit logging, and significant criminal penalties apply for unauthorised access.
Workplace surveillance Acts in Australia: NSW, ACT and the patchwork
Some states have specific workplace surveillance Acts; others rely on the Privacy Act and state surveillance-devices Acts. Here's the framework — particularly for NSW + ACT employers.
The Privacy Act employee records exemption (section 7B): what it covers and what it doesn't
Section 7B(3) of the Privacy Act 1988 exempts acts and practices of organisations relating to employee records from the Australian Privacy Principles. The carve-out is narrower than many employers think.
TIA Act data retention: the 2-year metadata regime explained
Telecommunications service providers must retain prescribed metadata for 2 years under the Telecommunications (Interception and Access) Act 1979. Here's the framework and the access rules.
Privacy Act 2024 automated decision-making transparency: commencing 10 December 2026
The Privacy and Other Legislation Amendment Act 2024 added automated decision-making transparency obligations. They commence 10 December 2026. Here's what entities must disclose in their privacy policies.
Frequently asked
If a customer says the product is 'faulty', is the consumer guarantee always available?
Generally yes — but only if it's a 'consumer' supply (under $100K or for personal/domestic/household use) and the goods failed to be of acceptable quality, fit for purpose, etc. Major failure (substantial enough to refuse the supply) → refund + damages. Minor failure → seller's choice of repair, replace, or refund. The seller — not the manufacturer — is the consumer's first port of call.
Can we restrict consumer guarantees with our T&Cs?
No. Section 64 of the ACL voids any term purporting to exclude, restrict, or modify consumer guarantees. Many retail T&Cs include 'no refunds after 7 days' or 'final sale' — these are unenforceable to the extent they purport to restrict consumer guarantees, and risk being a misleading representation under s 29.
We're under $3M turnover — is the Privacy Act really out of scope?
Probably yes for now, but the carve-in conditions matter. The small-business exemption does not apply if you handle health information, sell personal-information lists, contract to Government, or are related body corporate of an APP entity. Several Privacy Act reform tranches under consideration would close or substantially narrow the SBE.
Do we have to display the price including GST?
Yes — s 48 ACL component-pricing rule. A price advertised to consumers must include the total of all unavoidable charges (GST, mandatory surcharges, mandatory delivery). Optional add-ons can be separately displayed.
Is the gift card 3-year rule different in different states?
No — the rule is in the ACL (Cth), applies nationally, and was introduced 1 November 2019. State Fair Trading agencies enforce on behalf of the ACCC.
Greenwashing — what's the line?
Sustainability and ESG claims must be specific, substantiated, and verifiable. The ACCC published guidance in December 2023 setting eight principles: be specific, use clear language, don't omit material information, show your work, only compare to relevant baselines, don't claim future aspirations as current performance, use clear visual elements, comply with mandatory standards. Misleading sustainability claims are misleading conduct under s 18.
BNPL — what changes for retailers who embed Afterpay / Zip / Klarna?
Embedded BNPL puts the credit-license + LCCC obligations on the BNPL provider, not the retailer. Retailer obligations focus on: not misrepresenting the BNPL terms (s 18/29 ACL); applying ACL anti-hawking rules; not inducing unsuitable BNPL purchases. Direct BNPL (retailer is the credit provider) requires the modified credit licence + LCCC compliance.
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