Canonical HTML: https://unfairtrading.com/data/evidence/
Page title: Journey evidence worksheet | Unfair Trading Australia
Recorded content version: 2026-09-14
Editorial implementation guidance
# Journey evidence worksheet
Use the existing learning taxonomy to choose an evidence question. This worksheet is our implementation interpretation. It does not turn research terms into legal rules or classify a real business.
- Record the journey, release, date, user context and available starting state.
- Capture the complete sequence, visible options, wording, defaults and outcomes.
- Identify the applicable rule, scope, status and each element separately.
- Record evidence supporting and challenging the concern, legitimate explanations and unobserved steps.
- Assign a responsible decision maker, preserve the evidence and test the fairer alternative.
[Regulatory claims and source revisions](https://unfairtrading.com/data/) · [Readiness checklist](https://unfairtrading.com/readiness-checklist/)
Research term, legal mapping and possible evidence, derived from the existing pattern catalogue
Research term and journey; Legal mapping and status; Evidence to retain; Fairer alternative;
[Automatic attention capture](https://unfairtrading.com/unfair-trading-practices/automatic-attention-capture/)
Account Management, Pricing; ACL section 28B, inserted by the 2026 Act: Possible risk indicator. In account management and pricing journeys, the automatic attention capture mechanism may warrant review where it manipulates a consumer or unreasonably distorts the decision environment and causes, or is likely to cause, detriment. The forced action label and an interface similarity do not establish a contravention; the complete section 28B test, scope, facts and evidence must be applied from 1 July 2027.
Dark-pattern research taxonomy: Editorial analysis. The cited research sources support this working pattern within the forced action family. It is editorial implementation guidance, not an Australian statutory category, regulator finding or legal safe harbour.; - Annotated account management and pricing screenshots at each responsive breakpoint
- The complete state sequence before, during and after the consumer decision
- Design-system component, content, default and configuration records for the reviewed release
- Operational records substantiating price, availability, timing and eligibility claims
- Usability, accessibility, reversal, complaint and support evidence relevant to consumer impact
- A dated product and legal review record identifying evidence, uncertainties and release decisions; Require deliberate continuation or provide clear, persistent pause and disable controls with natural stopping cues.;
[Contact harvesting and coerced referrals](https://unfairtrading.com/unfair-trading-practices/contact-harvesting-and-coerced-referrals/)
Signup, Account Management; ACL section 28B, inserted by the 2026 Act: Possible risk indicator. In signup and account management journeys, the contact harvesting and coerced referrals mechanism may warrant review where it manipulates a consumer or unreasonably distorts the decision environment and causes, or is likely to cause, detriment. The forced action label and an interface similarity do not establish a contravention; the complete section 28B test, scope, facts and evidence must be applied from 1 July 2027.
Dark-pattern research taxonomy: Editorial analysis. The cited research sources support this working pattern within the forced action family. It is editorial implementation guidance, not an Australian statutory category, regulator finding or legal safe harbour.; - Annotated signup and account management screenshots at each responsive breakpoint
- The complete state sequence before, during and after the consumer decision
- Design-system component, content, default and configuration records for the reviewed release
- Operational records substantiating price, availability, timing and eligibility claims
- Usability, accessibility, reversal, complaint and support evidence relevant to consumer impact
- A dated product and legal review record identifying evidence, uncertainties and release decisions; Make contact access and referrals optional, granular and previewable; require affirmative confirmation for every recipient and message.;
[Forced or bundled consent](https://unfairtrading.com/unfair-trading-practices/forced-or-bundled-consent/)
Signup, Checkout; ACL section 28B, inserted by the 2026 Act: Possible risk indicator. In signup and checkout journeys, the forced or bundled consent mechanism may warrant review where it manipulates a consumer or unreasonably distorts the decision environment and causes, or is likely to cause, detriment. The forced action label and an interface similarity do not establish a contravention; the complete section 28B test, scope, facts and evidence must be applied from 1 July 2027.
Dark-pattern research taxonomy: Editorial analysis. The cited research sources support this working pattern within the forced action family. It is editorial implementation guidance, not an Australian statutory category, regulator finding or legal safe harbour.; - Annotated signup and checkout screenshots at each responsive breakpoint
- The complete state sequence before, during and after the consumer decision
- Design-system component, content, default and configuration records for the reviewed release
- Operational records substantiating price, availability, timing and eligibility claims
- Usability, accessibility, reversal, complaint and support evidence relevant to consumer impact
- A dated product and legal review record identifying evidence, uncertainties and release decisions; Separate distinct purposes, make optional uses genuinely optional, and provide an equally accessible refusal path.;
[Forced disclosure or excessive data request](https://unfairtrading.com/unfair-trading-practices/forced-disclosure-or-excessive-data-request/)
Pricing; ACL section 28B, inserted by the 2026 Act: Possible risk indicator. In pricing journeys, the forced disclosure or excessive data request mechanism may warrant review where it manipulates a consumer or unreasonably distorts the decision environment and causes, or is likely to cause, detriment. The forced action label and an interface similarity do not establish a contravention; the complete section 28B test, scope, facts and evidence must be applied from 1 July 2027.
Dark-pattern research taxonomy: Editorial analysis. The cited research sources support this working pattern within the forced action family. It is editorial implementation guidance, not an Australian statutory category, regulator finding or legal safe harbour.; - Annotated pricing screenshots at each responsive breakpoint
- The complete state sequence before, during and after the consumer decision
- Design-system component, content, default and configuration records for the reviewed release
- Operational records substantiating price, availability, timing and eligibility claims
- Usability, accessibility, reversal, complaint and support evidence relevant to consumer impact
- A dated product and legal review record identifying evidence, uncertainties and release decisions; Request only data necessary for the current goal, make secondary uses optional, and explain purpose and consequences clearly.;
[Forced registration](https://unfairtrading.com/unfair-trading-practices/forced-registration-and-data-disclosure/)
Checkout, Pricing; ACL section 28B(2), inserted by the 2026 Act: Possible risk indicator. Potentially applies when the gate forms part of manipulative or unreasonably distorting conduct and likely detriment results.
ACL section 28B(6)(d), inserted by the 2026 Act: Possible risk indicator. Offers a non-exhaustive example involving unreasonable obstruction of making or fulfilling a decision.; - field-by-field necessity register
- journey map for guest and account users
- consent and copy approvals
- data-flow diagram and retention decision
- support and cancellation test scripts
- abandonment and complaint analysis
- Annotated checkout and pricing screenshots at each responsive breakpoint
- The complete state sequence before, during and after the consumer decision
- Design-system component, content, default and configuration records for the reviewed release
- Operational records substantiating price, availability, timing and eligibility claims
- Usability, accessibility, reversal, complaint and support evidence relevant to consumer impact
- A dated product and legal review record identifying evidence, uncertainties and release decisions; Provide a clearly visible guest or no-account path unless registration is genuinely necessary, and explain necessity before collecting data.;
[Gamified or paid access coercion](https://unfairtrading.com/unfair-trading-practices/gamified-or-paid-access-coercion/)
Account Management; ACL section 28B, inserted by the 2026 Act: Possible risk indicator. In account management journeys, the gamified or paid access coercion mechanism may warrant review where it manipulates a consumer or unreasonably distorts the decision environment and causes, or is likely to cause, detriment. The forced action label and an interface similarity do not establish a contravention; the complete section 28B test, scope, facts and evidence must be applied from 1 July 2027.
Dark-pattern research taxonomy: Editorial analysis. The cited research sources support this working pattern within the forced action family. It is editorial implementation guidance, not an Australian statutory category, regulator finding or legal safe harbour.; - Annotated account management screenshots at each responsive breakpoint
- The complete state sequence before, during and after the consumer decision
- Design-system component, content, default and configuration records for the reviewed release
- Operational records substantiating price, availability, timing and eligibility claims
- Usability, accessibility, reversal, complaint and support evidence relevant to consumer impact
- A dated product and legal review record identifying evidence, uncertainties and release decisions; Disclose access conditions before acquisition and avoid making disproportionate repetition or surprise payment the practical path to expected functionality.;
[Bundled options](https://unfairtrading.com/unfair-trading-practices/bundled-options/)
Checkout, Pricing; ACL section 28B, inserted by the 2026 Act: Possible risk indicator. In checkout and pricing journeys, the bundled options mechanism may warrant review where it manipulates a consumer or unreasonably distorts the decision environment and causes, or is likely to cause, detriment. The interface interference label and an interface similarity do not establish a contravention; the complete section 28B test, scope, facts and evidence must be applied from 1 July 2027.
Dark-pattern research taxonomy: Editorial analysis. The cited research sources support this working pattern within the interface interference family. It is editorial implementation guidance, not an Australian statutory category, regulator finding or legal safe harbour.; - Annotated checkout and pricing screenshots at each responsive breakpoint
- The complete state sequence before, during and after the consumer decision
- Design-system component, content, default and configuration records for the reviewed release
- Operational records substantiating price, availability, timing and eligibility claims
- Usability, accessibility, reversal, complaint and support evidence relevant to consumer impact
- A dated product and legal review record identifying evidence, uncertainties and release decisions; Show component consequences and prices and provide granular, equally accessible choices where components are separable.;
[Choice or information overload](https://unfairtrading.com/unfair-trading-practices/choice-or-information-overload/)
Pricing, Signup; ACL section 28B, inserted by the 2026 Act: Possible risk indicator. In pricing and signup journeys, the choice or information overload mechanism may warrant review where it manipulates a consumer or unreasonably distorts the decision environment and causes, or is likely to cause, detriment. The interface interference label and an interface similarity do not establish a contravention; the complete section 28B test, scope, facts and evidence must be applied from 1 July 2027.
Dark-pattern research taxonomy: Editorial analysis. The cited research sources support this working pattern within the interface interference family. It is editorial implementation guidance, not an Australian statutory category, regulator finding or legal safe harbour.; - Annotated pricing and signup screenshots at each responsive breakpoint
- The complete state sequence before, during and after the consumer decision
- Design-system component, content, default and configuration records for the reviewed release
- Operational records substantiating price, availability, timing and eligibility claims
- Usability, accessibility, reversal, complaint and support evidence relevant to consumer impact
- A dated product and legal review record identifying evidence, uncertainties and release decisions; Structure choices around comparable dimensions, surface key consequences and avoid using volume to hide a default or preferred outcome.;
[Complex or inaccessible language](https://unfairtrading.com/unfair-trading-practices/complex-or-inaccessible-language/)
Cancellation, Checkout; ACL section 28B, inserted by the 2026 Act: Possible risk indicator. In cancellation and checkout journeys, the complex or inaccessible language mechanism may warrant review where it manipulates a consumer or unreasonably distorts the decision environment and causes, or is likely to cause, detriment. The interface interference label and an interface similarity do not establish a contravention; the complete section 28B test, scope, facts and evidence must be applied from 1 July 2027.
Dark-pattern research taxonomy: Editorial analysis. The cited research sources support this working pattern within the interface interference family. It is editorial implementation guidance, not an Australian statutory category, regulator finding or legal safe harbour.; - Annotated cancellation and checkout screenshots at each responsive breakpoint
- The complete state sequence before, during and after the consumer decision
- Design-system component, content, default and configuration records for the reviewed release
- Operational records substantiating price, availability, timing and eligibility claims
- Usability, accessibility, reversal, complaint and support evidence relevant to consumer impact
- A dated product and legal review record identifying evidence, uncertainties and release decisions; Use the user's selected language, plain structure and explained terminology for material consequences.;
[Disguised advertisement or action](https://unfairtrading.com/unfair-trading-practices/disguised-advertisement-or-action/)
Pricing; ACL section 28B, inserted by the 2026 Act: Possible risk indicator. In pricing journeys, the disguised advertisement or action mechanism may warrant review where it manipulates a consumer or unreasonably distorts the decision environment and causes, or is likely to cause, detriment. The interface interference label and an interface similarity do not establish a contravention; the complete section 28B test, scope, facts and evidence must be applied from 1 July 2027.
Dark-pattern research taxonomy: Editorial analysis. The cited research sources support this working pattern within the interface interference family. It is editorial implementation guidance, not an Australian statutory category, regulator finding or legal safe harbour.; - Annotated pricing screenshots at each responsive breakpoint
- The complete state sequence before, during and after the consumer decision
- Design-system component, content, default and configuration records for the reviewed release
- Operational records substantiating price, availability, timing and eligibility claims
- Usability, accessibility, reversal, complaint and support evidence relevant to consumer impact
- A dated product and legal review record identifying evidence, uncertainties and release decisions; Label advertising and action outcomes clearly before interaction and avoid mimicking unrelated controls or editorial content.;
[False hierarchy](https://unfairtrading.com/unfair-trading-practices/manipulative-choice-architecture/)
Signup, Subscription; ACL section 28B(1) to (2), inserted by the 2026 Act: Express rule. Prohibits the practice only where consumer connection, manipulation or unreasonable distortion, and likely detriment are all present.
ACL section 28B(6)(d), inserted by the 2026 Act: Possible risk indicator. Provides a non-exhaustive, non-per-se example concerning pressure or obstruction in a decision environment, including digital design.; - annotated screenshots for each responsive breakpoint
- design-system component states and copy variants
- inventory or reservation logic supporting urgency claims
- usability-test protocol and findings
- funnel, reversal and complaint data
- approval record linking design choices to reviewed risks
- Annotated signup and subscription screenshots at each responsive breakpoint
- The complete state sequence before, during and after the consumer decision
- Design-system component, content, default and configuration records for the reviewed release
- Operational records substantiating price, availability, timing and eligibility claims
- Usability, accessibility, reversal, complaint and support evidence relevant to consumer impact
- A dated product and legal review record identifying evidence, uncertainties and release decisions; Present parallel choices with comparable visual weight, affordance and accessibility, especially where outcomes differ in cost, privacy or commitment.;
[Feedforward ambiguity](https://unfairtrading.com/unfair-trading-practices/feedforward-ambiguity/)
Checkout, Account Management; ACL section 28B, inserted by the 2026 Act: Possible risk indicator. In checkout and account management journeys, the feedforward ambiguity mechanism may warrant review where it manipulates a consumer or unreasonably distorts the decision environment and causes, or is likely to cause, detriment. The interface interference label and an interface similarity do not establish a contravention; the complete section 28B test, scope, facts and evidence must be applied from 1 July 2027.
Dark-pattern research taxonomy: Editorial analysis. The cited research sources support this working pattern within the interface interference family. It is editorial implementation guidance, not an Australian statutory category, regulator finding or legal safe harbour.; - Annotated checkout and account management screenshots at each responsive breakpoint
- The complete state sequence before, during and after the consumer decision
- Design-system component, content, default and configuration records for the reviewed release
- Operational records substantiating price, availability, timing and eligibility claims
- Usability, accessibility, reversal, complaint and support evidence relevant to consumer impact
- A dated product and legal review record identifying evidence, uncertainties and release decisions; Name the material consequence in the action label or immediately adjacent disclosure before activation.;
[Hidden or ineffective material information](https://unfairtrading.com/unfair-trading-practices/hidden-or-ineffective-material-information/)
Pricing; ACL section 28B(6)(b), inserted by the 2026 Act: Possible risk indicator. Failure to disclose material information is a non-exhaustive example that may be an unfair trading practice.
ACL section 28B(6)(c), inserted by the 2026 Act: Possible risk indicator. Complex, ineffective, unclear, unintelligible, ambiguous, untimely or overwhelming disclosure is another non-exhaustive example.
ACL sections 18 and 29: Current law. Existing provisions may already address an omission or presentation that creates a misleading overall impression or false representation.; - material-information inventory
- annotated journey showing disclosure timing
- responsive screenshots and accessibility checks
- copy and legal approval history
- complaint, cancellation and refund themes
- user-comprehension test results
- Annotated pricing screenshots at each responsive breakpoint
- The complete state sequence before, during and after the consumer decision
- Design-system component, content, default and configuration records for the reviewed release
- Operational records substantiating price, availability, timing and eligibility claims
- Usability, accessibility, reversal, complaint and support evidence relevant to consumer impact
- A dated product and legal review record identifying evidence, uncertainties and release decisions; Present material information clearly, prominently and at the point where it can affect the decision; do not rely on optional expansion or late disclosure.;
[Confirmshaming and emotional pressure](https://unfairtrading.com/unfair-trading-practices/confirmshaming-and-emotional-pressure/)
Checkout, Cancellation; ACL section 28B(2), inserted by the 2026 Act: Possible risk indicator. Potentially applies where the language manipulates or unreasonably distorts the decision environment and causes or is likely to cause detriment.
ACL section 28B(6)(d), inserted by the 2026 Act: Possible risk indicator. Identifies unreasonable pressure in a decision environment as a non-exhaustive example.; - interface-copy inventory
- content-design principles and approval history
- screenshots of each choice state
- vulnerable-user and accessibility review
- cancellation and decline-path test results
- complaints and verbatim user feedback
- Annotated checkout and cancellation screenshots at each responsive breakpoint
- The complete state sequence before, during and after the consumer decision
- Design-system component, content, default and configuration records for the reviewed release
- Operational records substantiating price, availability, timing and eligibility claims
- Usability, accessibility, reversal, complaint and support evidence relevant to consumer impact
- A dated product and legal review record identifying evidence, uncertainties and release decisions; Use neutral, consequence-based labels and avoid shame, fear or moral judgement in decline or alternative actions.;
[Misleading reference pricing](https://unfairtrading.com/unfair-trading-practices/misleading-reference-pricing/)
Pricing; ACL section 28B, inserted by the 2026 Act: Possible risk indicator. In pricing journeys, the misleading reference pricing mechanism may warrant review where it manipulates a consumer or unreasonably distorts the decision environment and causes, or is likely to cause, detriment. The interface interference label and an interface similarity do not establish a contravention; the complete section 28B test, scope, facts and evidence must be applied from 1 July 2027.
Dark-pattern research taxonomy: Editorial analysis. The cited research sources support this working pattern within the interface interference family. It is editorial implementation guidance, not an Australian statutory category, regulator finding or legal safe harbour.; - Annotated pricing screenshots at each responsive breakpoint
- The complete state sequence before, during and after the consumer decision
- Design-system component, content, default and configuration records for the reviewed release
- Operational records substantiating price, availability, timing and eligibility claims
- Usability, accessibility, reversal, complaint and support evidence relevant to consumer impact
- A dated product and legal review record identifying evidence, uncertainties and release decisions; Use a truthful, representative comparison basis and explain the reference period or basis close to the claim.;
[Preselection and biased defaults](https://unfairtrading.com/unfair-trading-practices/preselection-and-biased-defaults/)
Checkout, Subscription; ACL section 28B(2), inserted by the 2026 Act: Possible risk indicator. Supplies the complete contextual test from commencement.
ACL section 28B(6)(c) to (d), inserted by the 2026 Act: Possible risk indicator. Ineffective material disclosure and pressure or obstruction through design may be relevant non-exhaustive examples.; - default-state inventory
- decision record for each material default
- screenshots before and after selection
- price and billing copy approvals
- removal, refund and complaint data
- accessibility interaction tests
- Annotated checkout and subscription screenshots at each responsive breakpoint
- The complete state sequence before, during and after the consumer decision
- Design-system component, content, default and configuration records for the reviewed release
- Operational records substantiating price, availability, timing and eligibility claims
- Usability, accessibility, reversal, complaint and support evidence relevant to consumer impact
- A dated product and legal review record identifying evidence, uncertainties and release decisions; Use a neutral or consumer-protective default and require affirmative selection for added cost, data use, tracking or commitment.;
[Pressured upselling](https://unfairtrading.com/unfair-trading-practices/pressured-upselling/)
Subscription, Checkout; ACL section 28B, inserted by the 2026 Act: Possible risk indicator. In subscription and checkout journeys, the pressured upselling mechanism may warrant review where it manipulates a consumer or unreasonably distorts the decision environment and causes, or is likely to cause, detriment. The interface interference label and an interface similarity do not establish a contravention; the complete section 28B test, scope, facts and evidence must be applied from 1 July 2027.
Dark-pattern research taxonomy: Editorial analysis. The cited research sources support this working pattern within the interface interference family. It is editorial implementation guidance, not an Australian statutory category, regulator finding or legal safe harbour.; - Annotated subscription and checkout screenshots at each responsive breakpoint
- The complete state sequence before, during and after the consumer decision
- Design-system component, content, default and configuration records for the reviewed release
- Operational records substantiating price, availability, timing and eligibility claims
- Usability, accessibility, reversal, complaint and support evidence relevant to consumer impact
- A dated product and legal review record identifying evidence, uncertainties and release decisions; Present price and commitment alternatives comparably and avoid preselecting or obscuring the more expensive outcome.;
[Trick question](https://unfairtrading.com/unfair-trading-practices/trick-question/)
Signup, Cancellation; ACL section 28B, inserted by the 2026 Act: Possible risk indicator. In signup and cancellation journeys, the trick question mechanism may warrant review where it manipulates a consumer or unreasonably distorts the decision environment and causes, or is likely to cause, detriment. The interface interference label and an interface similarity do not establish a contravention; the complete section 28B test, scope, facts and evidence must be applied from 1 July 2027.
Dark-pattern research taxonomy: Editorial analysis. The cited research sources support this working pattern within the interface interference family. It is editorial implementation guidance, not an Australian statutory category, regulator finding or legal safe harbour.; - Annotated signup and cancellation screenshots at each responsive breakpoint
- The complete state sequence before, during and after the consumer decision
- Design-system component, content, default and configuration records for the reviewed release
- Operational records substantiating price, availability, timing and eligibility claims
- Usability, accessibility, reversal, complaint and support evidence relevant to consumer impact
- A dated product and legal review record identifying evidence, uncertainties and release decisions; Use explicit action labels that name the resulting state, remove double negatives and verify that each response produces the consequence a user can reasonably predict.;
[Repeated prompting](https://unfairtrading.com/unfair-trading-practices/repeated-prompting/)
Signup, Checkout; ACL section 28B, inserted by the 2026 Act: Possible risk indicator. In signup and checkout journeys, the repeated prompting mechanism may warrant review where it manipulates a consumer or unreasonably distorts the decision environment and causes, or is likely to cause, detriment. The nagging label and an interface similarity do not establish a contravention; the complete section 28B test, scope, facts and evidence must be applied from 1 July 2027.
Dark-pattern research taxonomy: Editorial analysis. The cited research sources support this working pattern within the nagging family. It is editorial implementation guidance, not an Australian statutory category, regulator finding or legal safe harbour.; - Annotated signup and checkout screenshots at each responsive breakpoint
- The complete state sequence before, during and after the consumer decision
- Design-system component, content, default and configuration records for the reviewed release
- Operational records substantiating price, availability, timing and eligibility claims
- Usability, accessibility, reversal, complaint and support evidence relevant to consumer impact
- A dated product and legal review record identifying evidence, uncertainties and release decisions; Respect decline and dismissal, provide a durable preference, and limit reminders to justified, transparent intervals.;
[Account deletion obstruction](https://unfairtrading.com/unfair-trading-practices/account-deletion-obstruction/)
Account Management; ACL section 28B, inserted by the 2026 Act: Possible risk indicator. In account management journeys, the account deletion obstruction mechanism may warrant review where it manipulates a consumer or unreasonably distorts the decision environment and causes, or is likely to cause, detriment. The obstruction label and an interface similarity do not establish a contravention; the complete section 28B test, scope, facts and evidence must be applied from 1 July 2027.
Dark-pattern research taxonomy: Editorial analysis. The cited research sources support this working pattern within the obstruction family. It is editorial implementation guidance, not an Australian statutory category, regulator finding or legal safe harbour.; - Annotated account management screenshots at each responsive breakpoint
- The complete state sequence before, during and after the consumer decision
- Design-system component, content, default and configuration records for the reviewed release
- Operational records substantiating price, availability, timing and eligibility claims
- Usability, accessibility, reversal, complaint and support evidence relevant to consumer impact
- A dated product and legal review record identifying evidence, uncertainties and release decisions; Offer a clear self-service deletion route, distinguish deletion from deactivation, and confirm the resulting state.;
[Comparison prevention](https://unfairtrading.com/unfair-trading-practices/comparison-prevention/)
Pricing; ACL section 28B, inserted by the 2026 Act: Possible risk indicator. In pricing journeys, the comparison prevention mechanism may warrant review where it manipulates a consumer or unreasonably distorts the decision environment and causes, or is likely to cause, detriment. The obstruction label and an interface similarity do not establish a contravention; the complete section 28B test, scope, facts and evidence must be applied from 1 July 2027.
Dark-pattern research taxonomy: Editorial analysis. The cited research sources support this working pattern within the obstruction family. It is editorial implementation guidance, not an Australian statutory category, regulator finding or legal safe harbour.; - Annotated pricing screenshots at each responsive breakpoint
- The complete state sequence before, during and after the consumer decision
- Design-system component, content, default and configuration records for the reviewed release
- Operational records substantiating price, availability, timing and eligibility claims
- Usability, accessibility, reversal, complaint and support evidence relevant to consumer impact
- A dated product and legal review record identifying evidence, uncertainties and release decisions; Use consistent units, terminology and side-by-side material totals with accessible supporting detail.;
[Customer-support obstruction](https://unfairtrading.com/unfair-trading-practices/customer-support-obstruction/)
Account Management, Pricing; ACL section 28B, inserted by the 2026 Act: Possible risk indicator. In account management and pricing journeys, the customer-support obstruction mechanism may warrant review where it manipulates a consumer or unreasonably distorts the decision environment and causes, or is likely to cause, detriment. The obstruction label and an interface similarity do not establish a contravention; the complete section 28B test, scope, facts and evidence must be applied from 1 July 2027.
Dark-pattern research taxonomy: Editorial analysis. The cited research sources support this working pattern within the obstruction family. It is editorial implementation guidance, not an Australian statutory category, regulator finding or legal safe harbour.; - Annotated account management and pricing screenshots at each responsive breakpoint
- The complete state sequence before, during and after the consumer decision
- Design-system component, content, default and configuration records for the reviewed release
- Operational records substantiating price, availability, timing and eligibility claims
- Usability, accessibility, reversal, complaint and support evidence relevant to consumer impact
- A dated product and legal review record identifying evidence, uncertainties and release decisions; Provide a discoverable support route, preserve context, and offer viable escalation for unresolved material issues.;
[Dead end](https://unfairtrading.com/unfair-trading-practices/dead-end/)
Account Management, Cancellation; ACL section 28B, inserted by the 2026 Act: Possible risk indicator. In account management and cancellation journeys, the dead end mechanism may warrant review where it manipulates a consumer or unreasonably distorts the decision environment and causes, or is likely to cause, detriment. The obstruction label and an interface similarity do not establish a contravention; the complete section 28B test, scope, facts and evidence must be applied from 1 July 2027.
Dark-pattern research taxonomy: Editorial analysis. The cited research sources support this working pattern within the obstruction family. It is editorial implementation guidance, not an Australian statutory category, regulator finding or legal safe harbour.; - Annotated account management and cancellation screenshots at each responsive breakpoint
- The complete state sequence before, during and after the consumer decision
- Design-system component, content, default and configuration records for the reviewed release
- Operational records substantiating price, availability, timing and eligibility claims
- Usability, accessibility, reversal, complaint and support evidence relevant to consumer impact
- A dated product and legal review record identifying evidence, uncertainties and release decisions; Provide a functional completion route, preserve progress, and surface recoverable errors equally across options.;
[Cancellation friction](https://unfairtrading.com/unfair-trading-practices/cancellation-friction/)
Cancellation; ACL section 48F(1), inserted by the 2026 Act: Express rule. Requires a way to end, with every supplied way easy to find, straightforward and limited to reasonably necessary steps to end and protect the subscriber's interests.
ACL section 48F(2), inserted by the 2026 Act: Express rule. Requires at least one online exit where entry occurred online or the supplier offers online entry for the same kind of goods or services.
ACL sections 48G to 48H, inserted by the 2026 Act: Express rule. Define consumer and qualifying standard-form small-business subscription scope.
ACL section 28B(6)(a) and (d), inserted by the 2026 Act: Possible risk indicator. Provides non-exhaustive examples concerning legal rights/remedies and obstruction.; - entry-versus-exit journey comparison
- step-level necessity and security rationale
- responsive and accessibility test recordings
- cancellation completion and failure logs
- confirmation templates and delivery logs
- retention-script approvals
- complaints, chargebacks and cancellation-time data
- regulation recheck record
- Annotated cancellation screenshots at each responsive breakpoint
- The complete state sequence before, during and after the consumer decision
- Design-system component, content, default and configuration records for the reviewed release
- Operational records substantiating price, availability, timing and eligibility claims
- Usability, accessibility, reversal, complaint and support evidence relevant to consumer impact
- A dated product and legal review record identifying evidence, uncertainties and release decisions; Provide an easy-to-find, direct exit path with only necessary verification and clear completion confirmation.;
[Intermediate currency](https://unfairtrading.com/unfair-trading-practices/intermediate-currency/)
Checkout; ACL section 28B, inserted by the 2026 Act: Possible risk indicator. In checkout journeys, the intermediate currency mechanism may warrant review where it manipulates a consumer or unreasonably distorts the decision environment and causes, or is likely to cause, detriment. The obstruction label and an interface similarity do not establish a contravention; the complete section 28B test, scope, facts and evidence must be applied from 1 July 2027.
Dark-pattern research taxonomy: Editorial analysis. The cited research sources support this working pattern within the obstruction family. It is editorial implementation guidance, not an Australian statutory category, regulator finding or legal safe harbour.; - Annotated checkout screenshots at each responsive breakpoint
- The complete state sequence before, during and after the consumer decision
- Design-system component, content, default and configuration records for the reviewed release
- Operational records substantiating price, availability, timing and eligibility claims
- Usability, accessibility, reversal, complaint and support evidence relevant to consumer impact
- A dated product and legal review record identifying evidence, uncertainties and release decisions; Show the current real-money equivalent and total before commitment and avoid conversion structures that obscure or strand value.;
[Obstructed alternative](https://unfairtrading.com/unfair-trading-practices/obstructed-alternative/)
Checkout, Signup; ACL section 28B, inserted by the 2026 Act: Possible risk indicator. In checkout and signup journeys, the obstructed alternative mechanism may warrant review where it manipulates a consumer or unreasonably distorts the decision environment and causes, or is likely to cause, detriment. The obstruction label and an interface similarity do not establish a contravention; the complete section 28B test, scope, facts and evidence must be applied from 1 July 2027.
Dark-pattern research taxonomy: Editorial analysis. The cited research sources support this working pattern within the obstruction family. It is editorial implementation guidance, not an Australian statutory category, regulator finding or legal safe harbour.; - Annotated checkout and signup screenshots at each responsive breakpoint
- The complete state sequence before, during and after the consumer decision
- Design-system component, content, default and configuration records for the reviewed release
- Operational records substantiating price, availability, timing and eligibility claims
- Usability, accessibility, reversal, complaint and support evidence relevant to consumer impact
- A dated product and legal review record identifying evidence, uncertainties and release decisions; Place equivalent alternatives in the same decision context with comparable discoverability and no unnecessary steps.;
[Privacy maze](https://unfairtrading.com/unfair-trading-practices/privacy-maze/)
Account Management; ACL section 28B, inserted by the 2026 Act: Possible risk indicator. In account management journeys, the privacy maze mechanism may warrant review where it manipulates a consumer or unreasonably distorts the decision environment and causes, or is likely to cause, detriment. The obstruction label and an interface similarity do not establish a contravention; the complete section 28B test, scope, facts and evidence must be applied from 1 July 2027.
Dark-pattern research taxonomy: Editorial analysis. The cited research sources support this working pattern within the obstruction family. It is editorial implementation guidance, not an Australian statutory category, regulator finding or legal safe harbour.; - Annotated account management screenshots at each responsive breakpoint
- The complete state sequence before, during and after the consumer decision
- Design-system component, content, default and configuration records for the reviewed release
- Operational records substantiating price, availability, timing and eligibility claims
- Usability, accessibility, reversal, complaint and support evidence relevant to consumer impact
- A dated product and legal review record identifying evidence, uncertainties and release decisions; Provide a coherent privacy-control overview, consistent labels and direct controls for common restrictive choices.;
[Bait and switch](https://unfairtrading.com/unfair-trading-practices/bait-and-switch/)
Account Management, Checkout; ACL section 28B, inserted by the 2026 Act: Possible risk indicator. In account management and checkout journeys, the bait and switch mechanism may warrant review where it manipulates a consumer or unreasonably distorts the decision environment and causes, or is likely to cause, detriment. The sneaking label and an interface similarity do not establish a contravention; the complete section 28B test, scope, facts and evidence must be applied from 1 July 2027.
Dark-pattern research taxonomy: Editorial analysis. The cited research sources support this working pattern within the sneaking family. It is editorial implementation guidance, not an Australian statutory category, regulator finding or legal safe harbour.; - Annotated account management and checkout screenshots at each responsive breakpoint
- The complete state sequence before, during and after the consumer decision
- Design-system component, content, default and configuration records for the reviewed release
- Operational records substantiating price, availability, timing and eligibility claims
- Usability, accessibility, reversal, complaint and support evidence relevant to consumer impact
- A dated product and legal review record identifying evidence, uncertainties and release decisions; Make the action produce its represented result or disclose and obtain assent to any material change before commitment.;
[Drip pricing and mandatory fees](https://unfairtrading.com/unfair-trading-practices/drip-pricing-and-mandatory-fees/)
Checkout, Pricing; ACL section 48A(1) to (5), inserted by the 2026 Act: Express rule. Sets the product scope and the transaction-charge disclosure content, timing and presentation requirements.
ACL section 48A(6) to (8), inserted by the 2026 Act: Express rule. Defines base price and transaction-based charge and lists excluded amounts.
ACL section 48A(9) to (10), inserted by the 2026 Act: Express rule. Allows prescribed exclusions and preserves the operation of the existing section 48 single-price rule.; - fee taxonomy with legal rationale
- price-feed and affiliate inventory
- screenshots of every base-price placement
- calculation specification and test cases
- checkout totals and receipts
- regulation recheck record
- Annotated checkout and pricing screenshots at each responsive breakpoint
- The complete state sequence before, during and after the consumer decision
- Design-system component, content, default and configuration records for the reviewed release
- Operational records substantiating price, availability, timing and eligibility claims
- Usability, accessibility, reversal, complaint and support evidence relevant to consumer impact
- A dated product and legal review record identifying evidence, uncertainties and release decisions; Show unavoidable and transaction-linked charges with the price, including amount or method, applicability and inclusion status.;
[Subscription traps and automatic renewal](https://unfairtrading.com/unfair-trading-practices/subscription-traps-and-automatic-renewal/)
Subscription, Checkout; ACL sections 48B to 48C, inserted by the 2026 Act: Express rule. Define subscription contracts and exclude leases, real-property licences, hire-purchase, instalment-payment contracts, childcare, specified school tuition and prescribed kinds.
ACL section 48D, inserted by the 2026 Act: Express rule. Requires the offer to state that the arrangement would be a subscription and disclose liabilities, period, continuation, required notice, exit method and any prescribed matter with specified clarity and timing.
ACL section 48E, inserted by the 2026 Act: Express rule. For prescribed subscription contracts meeting the consumer or small-business requirement, requires prescribed information at each prescribed time and in the required manner.
ACL sections 48G to 48H, inserted by the 2026 Act: Express rule. Define consumer and small-business requirements and the standard-form-contract test for the subscription division.
ACL sections 18 and 29: Current law. May already apply to misleading subscription status, price, renewal or trial-conversion representations.; - contract-type and exclusion register
- pre-contract disclosure matrix
- annotated sign-up screenshots and call scripts
- billing-event and trial-conversion specification
- contract-version and transition inventory
- configurable notification rules and delivery logs
- complaints, refunds and chargeback analysis
- regulation recheck record
- Annotated subscription and checkout screenshots at each responsive breakpoint
- The complete state sequence before, during and after the consumer decision
- Design-system component, content, default and configuration records for the reviewed release
- Operational records substantiating price, availability, timing and eligibility claims
- Usability, accessibility, reversal, complaint and support evidence relevant to consumer impact
- A dated product and legal review record identifying evidence, uncertainties and release decisions; Present every material subscription, renewal and exit term clearly before assent and satisfy current notice rules.;
[Negative option or unauthorised transaction](https://unfairtrading.com/unfair-trading-practices/negative-option-or-unauthorised-transaction/)
Subscription, Cancellation; ACL section 28B, inserted by the 2026 Act: Possible risk indicator. In subscription and cancellation journeys, the negative option or unauthorised transaction mechanism may warrant review where it manipulates a consumer or unreasonably distorts the decision environment and causes, or is likely to cause, detriment. The sneaking label and an interface similarity do not establish a contravention; the complete section 28B test, scope, facts and evidence must be applied from 1 July 2027.
Dark-pattern research taxonomy: Editorial analysis. The cited research sources support this working pattern within the sneaking family. It is editorial implementation guidance, not an Australian statutory category, regulator finding or legal safe harbour.; - Annotated subscription and cancellation screenshots at each responsive breakpoint
- The complete state sequence before, during and after the consumer decision
- Design-system component, content, default and configuration records for the reviewed release
- Operational records substantiating price, availability, timing and eligibility claims
- Usability, accessibility, reversal, complaint and support evidence relevant to consumer impact
- A dated product and legal review record identifying evidence, uncertainties and release decisions; Obtain clear, specific assent before any paid consequence and do not treat silence or inactivity as a new authorisation.;
[Sneak into basket](https://unfairtrading.com/unfair-trading-practices/sneak-into-basket/)
Checkout; ACL section 28B, inserted by the 2026 Act: Possible risk indicator. In checkout journeys, the sneak into basket mechanism may warrant review where it manipulates a consumer or unreasonably distorts the decision environment and causes, or is likely to cause, detriment. The sneaking label and an interface similarity do not establish a contravention; the complete section 28B test, scope, facts and evidence must be applied from 1 July 2027.
Dark-pattern research taxonomy: Editorial analysis. The cited research sources support this working pattern within the sneaking family. It is editorial implementation guidance, not an Australian statutory category, regulator finding or legal safe harbour.; - Annotated checkout screenshots at each responsive breakpoint
- The complete state sequence before, during and after the consumer decision
- Design-system component, content, default and configuration records for the reviewed release
- Operational records substantiating price, availability, timing and eligibility claims
- Usability, accessibility, reversal, complaint and support evidence relevant to consumer impact
- A dated product and legal review record identifying evidence, uncertainties and release decisions; Add an item only after a deliberate selection, preserve removal through every recalculation and show the updated line item and total before commitment.;
[Activity messages](https://unfairtrading.com/unfair-trading-practices/activity-messages/)
Pricing; ACL section 28B, inserted by the 2026 Act: Possible risk indicator. In pricing journeys, the activity messages mechanism may warrant review where it manipulates a consumer or unreasonably distorts the decision environment and causes, or is likely to cause, detriment. The social proof label and an interface similarity do not establish a contravention; the complete section 28B test, scope, facts and evidence must be applied from 1 July 2027.
Dark-pattern research taxonomy: Editorial analysis. The cited research sources support this working pattern within the social proof family. It is editorial implementation guidance, not an Australian statutory category, regulator finding or legal safe harbour.; - Annotated pricing screenshots at each responsive breakpoint
- The complete state sequence before, during and after the consumer decision
- Design-system component, content, default and configuration records for the reviewed release
- Operational records substantiating price, availability, timing and eligibility claims
- Usability, accessibility, reversal, complaint and support evidence relevant to consumer impact
- A dated product and legal review record identifying evidence, uncertainties and release decisions; Use accurate, auditable and appropriately time-bounded activity data and explain what the metric represents.;
[Popularity claims](https://unfairtrading.com/unfair-trading-practices/popularity-claims/)
Pricing; ACL section 28B, inserted by the 2026 Act: Possible risk indicator. In pricing journeys, the popularity claims mechanism may warrant review where it manipulates a consumer or unreasonably distorts the decision environment and causes, or is likely to cause, detriment. The social proof label and an interface similarity do not establish a contravention; the complete section 28B test, scope, facts and evidence must be applied from 1 July 2027.
Dark-pattern research taxonomy: Editorial analysis. The cited research sources support this working pattern within the social proof family. It is editorial implementation guidance, not an Australian statutory category, regulator finding or legal safe harbour.; - Annotated pricing screenshots at each responsive breakpoint
- The complete state sequence before, during and after the consumer decision
- Design-system component, content, default and configuration records for the reviewed release
- Operational records substantiating price, availability, timing and eligibility claims
- Usability, accessibility, reversal, complaint and support evidence relevant to consumer impact
- A dated product and legal review record identifying evidence, uncertainties and release decisions; Use popularity claims only with a defined population, period and metric; document the calculation beside the claim or replace it with factual product information.;
[Testimonials or endorsements](https://unfairtrading.com/unfair-trading-practices/testimonials-or-endorsements/)
Pricing; ACL section 28B, inserted by the 2026 Act: Possible risk indicator. In pricing journeys, the testimonials or endorsements mechanism may warrant review where it manipulates a consumer or unreasonably distorts the decision environment and causes, or is likely to cause, detriment. The social proof label and an interface similarity do not establish a contravention; the complete section 28B test, scope, facts and evidence must be applied from 1 July 2027.
Dark-pattern research taxonomy: Editorial analysis. The cited research sources support this working pattern within the social proof family. It is editorial implementation guidance, not an Australian statutory category, regulator finding or legal safe harbour.; - Annotated pricing screenshots at each responsive breakpoint
- The complete state sequence before, during and after the consumer decision
- Design-system component, content, default and configuration records for the reviewed release
- Operational records substantiating price, availability, timing and eligibility claims
- Usability, accessibility, reversal, complaint and support evidence relevant to consumer impact
- A dated product and legal review record identifying evidence, uncertainties and release decisions; Use authentic, supportable testimonials and clearly disclose material commercial connections and limitations.;
[Countdown timer](https://unfairtrading.com/unfair-trading-practices/false-urgency-and-scarcity/)
Pricing, Checkout; ACL section 28B(2), inserted by the 2026 Act: Possible risk indicator. Potentially applies where a pressure device manipulates or unreasonably distorts the decision environment and causes or is likely to cause detriment.
ACL section 28B(6)(d), inserted by the 2026 Act: Possible risk indicator. Identifies unreasonable pressure in a decision environment as an example that may satisfy the prohibition.
ACL sections 18 and 29: Current law. May already apply where an urgency, stock, demand or duration claim is false or creates a misleading overall impression.; - inventory and offer-source logs
- promotion start and end approvals
- countdown implementation tests
- data freshness and failure-state rules
- screenshots with timestamps
- complaint and conversion-quality analysis
- Annotated pricing and checkout screenshots at each responsive breakpoint
- The complete state sequence before, during and after the consumer decision
- Design-system component, content, default and configuration records for the reviewed release
- Operational records substantiating price, availability, timing and eligibility claims
- Usability, accessibility, reversal, complaint and support evidence relevant to consumer impact
- A dated product and legal review record identifying evidence, uncertainties and release decisions; Use timers only for genuine deadlines, keep them consistent, and make the represented consequence occur at expiry.;
[High-demand claim](https://unfairtrading.com/unfair-trading-practices/high-demand-claim/)
Pricing; ACL section 28B, inserted by the 2026 Act: Possible risk indicator. In pricing journeys, the high-demand claim mechanism may warrant review where it manipulates a consumer or unreasonably distorts the decision environment and causes, or is likely to cause, detriment. The urgency label and an interface similarity do not establish a contravention; the complete section 28B test, scope, facts and evidence must be applied from 1 July 2027.
Dark-pattern research taxonomy: Editorial analysis. The cited research sources support this working pattern within the urgency family. It is editorial implementation guidance, not an Australian statutory category, regulator finding or legal safe harbour.; - Annotated pricing screenshots at each responsive breakpoint
- The complete state sequence before, during and after the consumer decision
- Design-system component, content, default and configuration records for the reviewed release
- Operational records substantiating price, availability, timing and eligibility claims
- Usability, accessibility, reversal, complaint and support evidence relevant to consumer impact
- A dated product and legal review record identifying evidence, uncertainties and release decisions; Base demand messages on current auditable data and state the metric and period without exaggeration.;
[Limited-time or reservation claim](https://unfairtrading.com/unfair-trading-practices/limited-time-or-reservation-claim/)
Pricing, Checkout; ACL section 28B, inserted by the 2026 Act: Possible risk indicator. In pricing and checkout journeys, the limited-time or reservation claim mechanism may warrant review where it manipulates a consumer or unreasonably distorts the decision environment and causes, or is likely to cause, detriment. The urgency label and an interface similarity do not establish a contravention; the complete section 28B test, scope, facts and evidence must be applied from 1 July 2027.
Dark-pattern research taxonomy: Editorial analysis. The cited research sources support this working pattern within the urgency family. It is editorial implementation guidance, not an Australian statutory category, regulator finding or legal safe harbour.; - Annotated pricing and checkout screenshots at each responsive breakpoint
- The complete state sequence before, during and after the consumer decision
- Design-system component, content, default and configuration records for the reviewed release
- Operational records substantiating price, availability, timing and eligibility claims
- Usability, accessibility, reversal, complaint and support evidence relevant to consumer impact
- A dated product and legal review record identifying evidence, uncertainties and release decisions; Use genuine fixed time limits, state the consequence accurately, and stop displaying the claim when it expires.;
[Low-stock claim](https://unfairtrading.com/unfair-trading-practices/low-stock-claim/)
Pricing, Checkout; ACL section 28B, inserted by the 2026 Act: Possible risk indicator. In pricing and checkout journeys, the low-stock claim mechanism may warrant review where it manipulates a consumer or unreasonably distorts the decision environment and causes, or is likely to cause, detriment. The urgency label and an interface similarity do not establish a contravention; the complete section 28B test, scope, facts and evidence must be applied from 1 July 2027.
Dark-pattern research taxonomy: Editorial analysis. The cited research sources support this working pattern within the urgency family. It is editorial implementation guidance, not an Australian statutory category, regulator finding or legal safe harbour.; - Annotated pricing and checkout screenshots at each responsive breakpoint
- The complete state sequence before, during and after the consumer decision
- Design-system component, content, default and configuration records for the reviewed release
- Operational records substantiating price, availability, timing and eligibility claims
- Usability, accessibility, reversal, complaint and support evidence relevant to consumer impact
- A dated product and legal review record identifying evidence, uncertainties and release decisions; Use current inventory data, avoid false precision, and remove or update the claim promptly when stock changes.;
Source comparison: 14 September 2026 · [Dated findings](https://unfairtrading.com/updates/act-enacted-baseline/) · [Status and updates](https://unfairtrading.com/data/history/)
**What this comparison covered**
The enacted text still sets commencement for 1 July 2027. The ACCC reiterated the forthcoming reforms on 3 September 2026. No dedicated prescribing instrument or final implementation guide was identified in the official locations checked on 14 September.
This source comparison checked the amending Act, register records, Treasury and ACCC material, and the research basis of the learning library. The latest ACL compilation was identified, but its full consumer-law volume could not be retrieved. Negative search results do not establish that no later instrument exists. Illustrative practice labels remain editorial analysis.
Editorial responsibility: [Tobias Reittinger](https://unfairtrading.com/authors/tobias-reittinger/). Published by Flowlane.
[Claims and sources](https://unfairtrading.com/data/) · [Status and updates](https://unfairtrading.com/data/history/) · [Methodology](https://unfairtrading.com/methodology/) · [Corrections](https://unfairtrading.com/corrections/)
Email updates
## Keep the implementation plan tied to current sources.
Receive source-backed updates without repeatedly checking every rule, practice and journey page.
[Get email updates](https://unfairtrading.com/newsletter/)
Double opt-in · No tracking · Unsubscribe at any time