E-commerce implementation path | Unfair Trading Australia

Review first

Trace every mandatory charge, inventory or urgency claim, default and material condition. Confirm that mobile and guest-checkout variants preserve the same information and practical choices. Competition and Consumer Amendment (Unfair Trading Practices) Act 2026 Competition and Consumer Act 2010, including Schedule 2: Australian Consumer Law

Evidence pack

Keep campaign and product claims, price components, inventory logic, checkout variants, experiment records, cancellation and return controls, complaints and reversal data. Competition and Consumer Amendment (Unfair Trading Practices) Act 2026 Competition and Consumer Act 2010, including Schedule 2: Australian Consumer Law

Industry journey map

Review the complete customer journey

An e-commerce review should follow a realistic purchase from the first campaign or search result to the receipt, then continue into account, return and cancellation states where relevant. The same product can have materially different journeys for mobile, guest checkout, loyalty members, marketplace referrals and personalised offers. Treat those variants as evidence, not edge cases. The aim is to understand the overall decision environment: what price and availability the consumer expected, which options were introduced, what effort was already invested and whether a fair route remained practical at every step. Include the hand-offs between advertising, catalogue, pricing, experimentation, fulfilment and support systems. A compliant-looking template cannot answer the review if a feed, rule or campaign changes the state a particular consumer actually received.

1Campaign and product discovery
2Product choice and configuration
3Basket and checkout
4Confirmation, fulfilment and returns

Journey review matrix for E-commerce implementation path
Decision point	Review focus	Evidence to retain	Suggested lead
Campaign and product discovery	Establish the first commercial impression before the consumer has invested effort in configuration or checkout.	Campaign, search, product, basket, payment and receipt captures for the same test identity and timestamp.	Product and marketing
Product choice and configuration	Review variants, warranties, bundles, memberships and defaults before they reach the basket.	A price-component table showing amount, calculation, inclusion, optionality, owner and legal-review status.	Product and UX
Basket and checkout	Trace every change in payable amount, selected item and material condition through to payment.	Inventory and urgency substantiation with denominator, refresh interval and fallback behaviour.	Engineering and product
Confirmation, fulfilment and returns	Verify that the durable record and operational outcome match the interface promise.	Default, recommendation and experiment configuration tied to a release and approval record.	Operations and compliance

Original Flowlane implementation map assembled from this guide’s reviewed journey stages and evidence plan. Suggested leads are workflow prompts, not legal allocations.

Journey stages

Decision points to test

Stage 1Campaign and product discovery

Establish the first commercial impression before the consumer has invested effort in configuration or checkout.

Does the landing state preserve the advertised price, eligibility, stock and delivery qualification?
Can the team reproduce reference prices, countdowns, popularity messages and personalised claims from a system of record?
Are sponsored rankings, marketplace relationships and comparison criteria apparent where they affect selection?

Stage 2Product choice and configuration

Review variants, warranties, bundles, memberships and defaults before they reach the basket.

Is the chosen variant genuinely available at the displayed amount and on the stated terms?
Are care plans, memberships and add-ons optional in presentation as well as contract wording?
Can a consumer compare the base product with bundles using consistent units and feature definitions?

Stage 3Basket and checkout

Trace every change in payable amount, selected item and material condition through to payment.

Was every optional item affirmatively selected, and can it be removed without avoidable persuasion?
Where do mandatory delivery, service or transaction charges first become known and how are they retained?
Do account prompts, scarcity messages or save offers interrupt the intended payment task?

Stage 4Confirmation, fulfilment and returns

Verify that the durable record and operational outcome match the interface promise.

Does the receipt identify products, charges, recurring status, delivery and key conditions?
Can support see the same version and state the consumer accepted?
Are return, refund and cancellation controls discoverable without contradicting statutory rights?

Legal information layers

Do not collapse current and future rules

The same journey can raise different questions under current law, provisions commencing on 1 July 2027 and later implementation material. Each layer below keeps its own status and must be applied to its own elements.

Existing ACL

Current enforcement

Sections 18, 29, 48 and other current provisions continue to apply to representations, overall impressions and component pricing on their own elements. Current cases and regulator material should retain their actual procedural status.

Section 48A transaction charges

Commences 1 July 2027

Where the enacted trigger and definitions are met, specified charge information must accompany the base price with the required presentation. Optional charges and exclusions still require classification.

Section 28B decision environment

Commences 1 July 2027

A default, omission, pressure message or obstructive sequence is not automatically prohibited. Apply the consumer connection, conduct limb and actual or likely detriment to the complete facts.

Implementation detail

Guidance pending

Later regulation or regulator guidance may refine specified questions. Keep taxonomies and controls configurable and do not present editorial workflow advice as an official safe harbour.

Evidence plan

Build a reviewable record

Campaign, search, product, basket, payment and receipt captures for the same test identity and timestamp.
A price-component table showing amount, calculation, inclusion, optionality, owner and legal-review status.
Inventory and urgency substantiation with denominator, refresh interval and fallback behaviour.
Default, recommendation and experiment configuration tied to a release and approval record.
Order events proving what was selected, charged, fulfilled, cancelled, refunded or returned.
Complaint, abandonment and support-contact evidence capable of testing the stated detriment hypothesis.

Release gate

Questions before release

Which journey states changed, including mobile, guest, loyalty and referral variants?
Does every price surface still use the intended components and current calculation rules?
What operational evidence supports each urgency, popularity or availability claim?
Can a consumer decline every optional item without losing the intended core purchase?
Will the receipt and support record reveal the same terms and choices shown at payment?

Evidence base

Sources

Competition and Consumer Amendment (Unfair Trading Practices) Act 2026Federal Register of Legislation · Primary · checked 2026-09-14 · C2026A00064
Competition and Consumer Act 2010, including Schedule 2: Australian Consumer LawFederal Register of Legislation · Primary · checked 2026-09-14 · C2004A00109
Manipulative conduct in the digital economy, pricing claims and competition in essential services among ACCC priorities for year aheadAustralian Competition and Consumer Commission · Primary · checked 2026-08-09