Who must comply with Food and Grocery Code of Conduct (now mandatory)?

Major supermarkets bound by mandatory Code with civil penalties from April 2025.

Food and Grocery Code of Conduct mandatory from April 2025 (was voluntary). Applies to Coles, Woolworths, Aldi, Metcash (above turnover thresholds). Sets supplier protections, retaliation prohibitions + ACCC complaint pathway. Civil penalties up to $10M for serious breaches.

Applies only if you are a large grocery retailer or supply one. Whether it applies turns on a fact that no industry, structure or size settles on its own.

How the regulator frames it: Major supermarkets above threshold + their suppliers.

What triggers it: Mandatory commencement April 2025.

Jurisdiction: Commonwealth law, so the test is the same in every state and territory.

Outcome across the 35 industries Rules Mate maps (3 of 35: only if a further fact applies; 32 of 35: no).

Structure does not change the answer in the 3 industries it can reach: for every structure the answer is "only if a further fact applies".

Size does not change the answer in the 3 industries it can reach: at every size band the answer is "only if a further fact applies".

Each line is one run of the Rules Mate applicability engine for a single business profile, with the reason the engine gives:

• Pty Ltd company in real estate agents with 6–19 employees, turnover $1M–$3M: does not apply. Requires a trigger outside this questionnaire.
• Pty Ltd company in retail trade with 6–19 employees, turnover $1M–$3M: check whether it applies. applies only if you are a large grocery retailer or supply one.

The engine shows this obligation as "check whether this applies" when a business has industry: Retail trade / Manufacturing / Agriculture, forestry & fishing. It then applies only if you are a large grocery retailer or supply one. That fact is not something Rules Mate can infer from industry, structure or size.

When due

Continuous.

Frequency

Ongoing

Evidence to keep

Code-compliant supplier agreements; dispute resolution records; ACCC + Code Reviewer engagement.

In force from

1 April 2025

Status

Current

Priority

Critical

Maximum penalty: Civil penalties up to ~$10M for serious code breaches.

Rules Mate has not yet classified the audit or assurance level for this obligation. Any audit, review or certification requirement is set by the regulator source listed below.

• F+G Code becomes mandatory + civil penalty: 1 April 2025 (one-off). F+G Code becomes mandatory + civil penalties applicable.

• ACCC enforcement under mandatory F+G Code from April 2025 (2025): Supermarket-supplier dynamics under structural review — supplier protections newly enforceable.

• Franchising Code of Conduct (mandatory industry code): Mandatory Code regulating franchise sale, disclosure, dispute resolution.
• Notify ACCC of acquisitions meeting mandatory merger thresholds: From 1 January 2026, mandatory merger notification regime kicks in.
• Dairy Code of Conduct (mandatory): Mandatory Code governing milk supply agreements between dairy farmers + processors.

Rules Mate tracks 4 published obligations tagged "competition", 3 of them rated critical. For a professional services Pty Ltd company with 6–19 employees operating in every state, 0 of those apply outright. This obligation is rated critical priority, and is an ongoing duty.

Regulated by Australian Competition and Consumer Commission.

ACCC: Competition and consumer regulator administering the Competition and Consumer Act 2010 and Australian Consumer Law, plus industry codes and infrastructure access regimes.

• Australian Competition and Consumer Commission

CCA: Australia's competition + consumer protection law.

• Competition and Consumer Act 2010

Free tools that help with this obligation:

• Compliance calendar builder