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Page title: Subscription cancellation under section 48F | Unfair Trading Australia

Recorded content version: 2026-09-14

Australian implementation guide

# Subscription cancellation under section 48F

Section 48F requires every supplied way to end a covered subscription to be easy to find, straightforward and limited to steps reasonably necessary to end the contract and protect the subscriber’s interests. At least one online exit is required where entry occurred online or the supplier offers online entry for the same kind of goods or services.

Commences 1 July 202714 September 2026

**Every exit route**

Easy to find and straightforward

**Steps**

Only reasonably necessary ending and subscriber-protection steps

**Online trigger**

Online entry by subscriber or online entry offered for the same kind

## Statements and evidence

Source comparisons and retained baselines are identified separately; no personal legal review is implied. [Data coverage and date meanings](https://unfairtrading.com/data/).

**Subscription cancellation under section 48F: Legal fact**

Section 48F requires every supplied way to end a covered subscription to be easy to find, straightforward and limited to steps reasonably necessary to end the contract and protect the subscriber’s interests. At least one online exit is required where entry occurred online or the supplier offers online entry for the same kind of goods or services.

Status: Commences 1 July 2027

Earlier source baseline: 2026-08-09. Source comparison: 2026-09-14. Automated source-content comparison. 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.

Revision: au-cancellation-test@f5802e0d99cab3461d60232148e7dcc74440cd9b71c87766692123a5e6b9a5a7

- [Competition and Consumer Amendment (Unfair Trading Practices) Act 2026](https://www.legislation.gov.au/C2026A00064/asmade): supports. Schedule 1, inserted ACL section 48F

- [Competition and Consumer Act 2010, including Schedule 2: Australian Consumer Law](https://www.legislation.gov.au/C2004A00109/latest): qualifies. Context and qualifications in the linked source; see the article source list.

- [Manipulative conduct in the digital economy, pricing claims and competition in essential services among ACCC priorities for year ahead](https://www.accc.gov.au/media-release/manipulative-conduct-in-the-digital-economy-pricing-claims-and-competition-in-essential-services-among-accc-priorities-for-year-ahead): qualifies. Context and qualifications in the linked source; see the article source list.

[Cite or inspect this claim](https://unfairtrading.com/data/#au-cancellation-test)

**ACL section 48F: Legal fact**

At least one ending method; every supplied method easy to find, straightforward and limited to steps reasonably necessary to end the contract and protect subscriber interests, plus the online-route trigger.

Status: Commences 1 July 2027

Earlier source baseline: 2026-08-09. Source comparison: 2026-09-14. Automated source-content comparison. 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.

Revision: au-s48f@30019fd69c29d9fbf0fabc664f0cc55c5d2c6a6ba4a409ed2d95e111e0dd5814

- [Competition and Consumer Amendment (Unfair Trading Practices) Act 2026](https://www.legislation.gov.au/C2026A00064/asmade): supports. Act No. 64, 2026, Schedule 1, ACL section 48F

[Cite or inspect this claim](https://unfairtrading.com/data/#au-s48f)

## What does “reasonably necessary” protect?

Section 48F does not name identity, fraud, access or retention controls as automatic safe harbours. Every step in every supplied method must be assessed against the enacted standard: whether it is reasonably necessary to end the contract and protect the subscriber’s interests. [↗Competition and Consumer Amendment (Unfair Trading Practices) Act 2026](https://www.legislation.gov.au/C2026A00064/asmade)

## When is an online exit required?

The trigger is broader than whether the particular subscriber joined online. It also applies where the supplier offers an online entry route for a subscription for the same kind of goods or services. [↗Competition and Consumer Amendment (Unfair Trading Practices) Act 2026](https://www.legislation.gov.au/C2026A00064/asmade)

## Which contracts and transition rules matter?

The section uses the consumer or qualifying standard-form small-business scope in sections 48G to 48H. Transitional section 312 addresses post-commencement contracts and relevant renewal, extension, continuation or variation of earlier contracts. [↗Competition and Consumer Amendment (Unfair Trading Practices) Act 2026](https://www.legislation.gov.au/C2026A00064/asmade)

## What does this look like in a customer journey?

Illustrative example 1 · Online entry and telephone-only exit

A fictional meal service accepts online signup in three steps but requires a weekday telephone call, repeated questions and a retention interview before it will process an ending request.

Why it may matter: The online-route trigger may be engaged from commencement, and every supplied method must meet the easy-to-find, straightforward and reasonably-necessary-steps standards. The exact contract and scope still require checking.

Illustrative example 2 · Every ending route loops through retention

A fictional streaming service offers account, chat and telephone ending routes, but each sends the subscriber through five changing save offers and resets the request if one screen is closed.

Why it may matter: Section 48F applies its standard to every ending method the supplier provides, not merely one nominal route. The same facts may also be relevant to section 28B only if its full test is met.

Illustrative customer journey

### Interface comparison

Potentially problematicWait: choose another deal

Wait: choose another deal. Five save screens must be declined before the ending request continues

Five save screens must be declined before the ending request continues

→

Neutral alternativeEnd subscription on 31 August

End subscription on 31 August. Review consequences · Confirm ending

Review consequences · Confirm ending

Abstract comparison between a five-screen retention loop that resets an ending request and a direct ending flow showing the date, consequences and confirmation.Provenance: Original abstract interface created by the portal editorial team; no real business, product, customer or interface is depicted.

## What is a fairer or lower-risk alternative?

Supply at least one way to end and apply the enacted standard to every method provided. Add an online route when section 48F(2) triggers it, retain only steps reasonably necessary to end the contract and protect subscriber interests, and provide clear evidence of completion without claiming a one-click or same-channel safe harbour.

## What is regulated, proposed or still open?

Status and source mapping for Subscription cancellation under section 48F

Evidence layer; Status; What the source supports;

Section 48F ending methods; Commences 1 July 2027; At least one ending method is required; every method the supplier provides must be easy to find, straightforward and limited to steps reasonably necessary to end the contract and protect subscriber interests. An online method is required only on the section 48F(2) trigger. [↗Competition and Consumer Amendment (Unfair Trading Practices) Act 2026](https://www.legislation.gov.au/C2026A00064/asmade);

Possible section 28B overlap; Commences 1 July 2027; Impeding rights or obstructing a decision may also be relevant under section 28B(6)(a) or (d), but only if the complete section 28B test is met. [↗Competition and Consumer Amendment (Unfair Trading Practices) Act 2026](https://www.legislation.gov.au/C2026A00064/asmade);

Existing enforcement context; Current enforcement; Existing ACL provisions may apply now. The HelloFresh/Youfoodz and Microsoft proceedings are allegations, not liability findings, and are not section 48F enforcement. [↗Competition and Consumer Act 2010, including Schedule 2: Australian Consumer Law](https://www.legislation.gov.au/C2004A00109/latest)[↗HelloFresh and Youfoodz in court over alleged subscription traps](https://www.accc.gov.au/media-release/hellofresh-and-youfoodz-in-court-over-alleged-subscription-traps)[↗Microsoft in court for allegedly misleading millions of Australians over Microsoft 365 subscriptions](https://www.accc.gov.au/media-release/microsoft-in-court-for-allegedly-misleading-millions-of-australians-over-microsoft-365-subscriptions);

Prescribed exceptions; Regulation pending; Section 48F(3) permits prescribed exceptions. The core ending-method duty does not depend on an exception being prescribed. [↗Competition and Consumer Amendment (Unfair Trading Practices) Act 2026](https://www.legislation.gov.au/C2026A00064/asmade);

Regulator implementation material; Guidance pending; Government funding and committee material anticipate ACCC education or guidance; no dedicated final guide is treated as published. [↗Unfair trading tricks and traps to be banned](https://ministers.treasury.gov.au/ministers/andrew-leigh-2025/media-releases/unfair-trading-tricks-and-traps-be-banned)[↗Inquiry into the Competition and Consumer Amendment (Unfair Trading Practices) Bill 2026](https://www.aph.gov.au/Parliamentary_Business/Committees/Senate/Economics/UnfairTradingBill2026);

Ending-flow and evidence recommendations; Editorial implementation guidance; The portal’s confirmation, testing and evidence suggestions are not safe harbours and do not replace the enacted test for every supplied method. [↗Competition and Consumer Amendment (Unfair Trading Practices) Act 2026](https://www.legislation.gov.au/C2026A00064/asmade);

## What should teams review?

- Does the arrangement meet the subscription and subscriber-scope conditions for section 48F?

- Can a subscriber find and complete every supplied method without avoidable obstruction?

- Which ending function or subscriber interest makes each retained step reasonably necessary?

- Does either online-entry trigger apply to the same kind of goods or services?

### Evidence to retain

- Entry-channel inventory and ending-route map

- Step-level reasonably-necessary assessment and approvals

- Responsive completion tests, event records and durable confirmation examples

## Section 48F cancellation evidence checklist

Your selections stay in this browser. This is a planning aid, not a compliance assessment.

0 of 6 reviewed

Product: Every supplied exit route is easy to find from account and help surfaces.Navigation map and timed user test.UX: Each route is straightforward and states the effective date and consequences.Annotated responsive journey captures.Legal: Every required step protects ending accuracy or a subscriber interest.Step-level necessity rationale and approval.Engineering: At least one online exit exists where the section 48F(2) trigger is met.Entry-channel catalogue and online completion test.Support: Completion generates an immediate durable confirmation and support can verify status.Event schema, sample receipt and support runbook.Operations: Renewal, extension, continuation and variation events identify contracts entering scope.Contract-version and lifecycle transition map.

[Flowlane](https://www.getflowlane.com/?utm_source=unfairtrading.com&utm_medium=referral&utm_campaign=guide-subscription-cancellation-section-48f): It follows an available account and cancellation path to record route finding, steps, retention prompts and the completion state. Your team assesses each step under section 48F and applicable current law; the scanner does not certify the path. [Scan a cancellation path →](https://www.getflowlane.com/?utm_source=unfairtrading.com&utm_medium=referral&utm_campaign=guide-subscription-cancellation-section-48f)

Evidence base

## Sources

- [Competition and Consumer Amendment (Unfair Trading Practices) Act 2026](https://www.legislation.gov.au/C2026A00064/asmade)Federal Register of Legislation · Primary · checked 2026-09-14 · C2026A00064

- [Competition and Consumer Act 2010, including Schedule 2: Australian Consumer Law](https://www.legislation.gov.au/C2004A00109/latest)Federal 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 ahead](https://www.accc.gov.au/media-release/manipulative-conduct-in-the-digital-economy-pricing-claims-and-competition-in-essential-services-among-accc-priorities-for-year-ahead)Australian Competition and Consumer Commission · Primary · checked 2026-08-09

- [HelloFresh and Youfoodz in court over alleged subscription traps](https://www.accc.gov.au/media-release/hellofresh-and-youfoodz-in-court-over-alleged-subscription-traps)Australian Competition and Consumer Commission · Primary · checked 2026-09-14

- [Microsoft in court for allegedly misleading millions of Australians over Microsoft 365 subscriptions](https://www.accc.gov.au/media-release/microsoft-in-court-for-allegedly-misleading-millions-of-australians-over-microsoft-365-subscriptions)Australian Competition and Consumer Commission · Primary · checked 2026-09-14

- [Unfair trading tricks and traps to be banned](https://ministers.treasury.gov.au/ministers/andrew-leigh-2025/media-releases/unfair-trading-tricks-and-traps-be-banned)Treasury Ministers · Primary · checked 2026-09-14

- [Inquiry into the Competition and Consumer Amendment (Unfair Trading Practices) Bill 2026](https://www.aph.gov.au/Parliamentary_Business/Committees/Senate/Economics/UnfairTradingBill2026)Senate Economics Legislation Committee · Primary · checked 2026-08-09

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.

Editorial responsibility does not indicate a personal legal review. Original studies and official documents retain their named authors.

**Cite this page**

Subscription cancellation under section 48F | Unfair Trading Australia. Editorial responsibility: Tobias Reittinger. Unfair Trading Australia. Content version: 2026-09-14. [https://unfairtrading.com/subscription-cancellation-section-48f/](https://unfairtrading.com/subscription-cancellation-section-48f/)

[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/)

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