Obstruction · Australia

Cancellation friction

From 1 July 2027, section 48F will require every supplied cancellation method for a covered consumer or small-business subscription to be easy to find, straightforward and limited to reasonably necessary steps. An online method is required where the subscriber entered online or the supplier offers online entry for the same kind of subscription. Section 28B may also apply to obstructed decisions or legal rights.

Commences 1 July 2027
Family
Obstruction
Also known as
  • roach motel
  • click fatigue
  • hard to unsubscribe
  • online sign-up but phone-only exit
  • repeated retention offers
  • unnecessary identity checks
  • cancellation link buried
  • unclear completion state
  • hard-to-cancel subscription
  • obstructed exit
  • cancellation maze
  • save-flow friction
  • Hard to cancel or opt out
Journey stages
See visual examplesBrowse all unfair trading practices

Definition

What is this pattern?

Ending an existing subscription, recurring service or permission is made difficult to find or complete through unnecessary steps or channel asymmetry. This is a design and research taxonomy for learning and evidence review, not a statutory offence label or an automatic finding that an interface is unlawful.

How it works

Ending an existing subscription, recurring service or permission is made difficult to find or complete through unnecessary steps or channel asymmetry. Ending or refusing a service requires materially more steps, time or channel changes than entry, increasing the cost of completing an already stated exit intention.

Warning signs

  • The user is trying to terminate or opt out of an existing relationship.
  • The route is difficult to find, non-straightforward or includes steps beyond those reasonably necessary.
  • Completion is verified through the resulting account or subscription state.

Potential harms

  • Channel switching and avoidable delay may cause extra charges or prevent completion.
  • Repeated friction can delay an intended exit and increase the chance of another billing cycle.

Learn by comparison

What does this look like?

These fictional examples make the design mechanism easier to recognise. They do not depict a real company and do not establish that an individual interface is unlawful.

Illustrative example 1 · Online signup requires telephone cancellation

A fictional streaming service accepts signup in three online steps but requires a weekday telephone call, repeated identity questions and a retention interview to cancel.

Potential consumer harm: Channel switching and avoidable delay may cause extra charges or prevent completion.

Illustrative example 2 · Five save offers block the final exit

A fictional account shows a new discount, pause offer or survey after every click on “Cancel”, and the final confirmation appears only after five refusals.

Potential consumer harm: Repeated friction can delay an intended exit and increase the chance of another billing cycle.

Illustrative example 3 · Online sign-up, telephone-only exit

A streaming service accepts sign-up in three online steps but requires a weekday telephone call, repeated identity questions and a retention interview to cancel.

Potential consumer harm: Section 48F's online trigger would apply from commencement, and the extra steps may fail the straightforward and reasonably-necessary standards.

Illustrative example 4 · Cancellation link loops to retention offers

Each click on 'cancel plan' opens a new discount screen; the final confirmation appears only after five declines and uses a visually dominant 'keep plan' control.

Potential consumer harm: The repeated save flow may make cancellation hard to find or non-straightforward and may also unreasonably obstruct the subscriber's decision.

Streaming subscriptionCancellation

Online signup requires telephone cancellation

A fictional streaming service accepts signup in three online steps but requires a weekday telephone call, repeated identity questions and a retention interview to cancel.

Potentially problematicCall us to discuss your plan
Neutral alternativeEnd subscription online

Why the first version can mislead: The route adds avoidable effort between the user’s stated intention and completion. In this streaming subscription example, the obstacle is: “The online account offers no completed cancellation route.” Evidence should show whether the alternative remains usable and whether “Confirm end date” reaches the represented state. Channel switching and avoidable delay may cause extra charges or prevent completion.

What a fairer design does: Provide a findable online route with proportionate verification and a durable cancellation receipt.

Show annotated differences (4)
Potentially problematic version
  • The online account offers no completed cancellation route.Why this state matters: The route adds avoidable effort between the user’s stated intention and completion. In this streaming subscription example, the obstacle is: “The online account offers no completed cancellation route.” Evidence should show whether the alternative remains usable and whether “Confirm end date” reaches the represented state. Channel switching and avoidable delay may cause extra charges or prevent completion.
  • Obscured outcome: upcomingReview prompt: How many steps, waits and channel changes separate “Weekdays 9 to 16 only” from the completed streaming subscription outcome?
Neutral alternative
  • Necessary verification, effective date and confirmation are handled in one route.Fairer design: Provide a findable online route with proportionate verification and a durable cancellation receipt.
  • Request recorded: Confirm end dateReview prompt: Count steps, waits, offers and channel changes through final confirmation; where does the route meet “The user is trying to terminate or opt out of an existing relationship”?
Review questions (3)
  • How many steps, waits and channel changes separate “Weekdays 9 to 16 only” from the completed streaming subscription outcome?
  • Count steps, waits, offers and channel changes through final confirmation; where does the route meet “The user is trying to terminate or opt out of an existing relationship”?
  • Measure the same task through the clearest available route: does the effort difference persist once “Reasonable authentication and fraud controls” is accounted for?
Side-by-side streaming subscription interface showing “Call us to discuss your plan” and the clearer alternative “End subscription online”.Provenance: Original hypothetical streaming subscription example created for this library; no real business, product or interface is depicted.
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Meal-plan accountCancellation

Five save offers block the final exit

A fictional account shows a new discount, pause offer or survey after every click on “Cancel”, and the final confirmation appears only after five refusals.

Potentially problematicBefore you go
Neutral alternativeConfirm cancellation

Why the first version can mislead: The route adds avoidable effort between the user’s stated intention and completion. In this meal-plan account example, the obstacle is: “Five sequential retention steps stand between request and confirmation.” Evidence should show whether the alternative remains usable and whether “End deliveries” reaches the represented state. Repeated friction can delay an intended exit and increase the chance of another billing cycle.

What a fairer design does: Keep optional save offers non-blocking and provide a stable direct path to confirmation.

Show annotated differences (4)
Potentially problematic version
  • Five sequential retention steps stand between request and confirmation.Why this state matters: The route adds avoidable effort between the user’s stated intention and completion. In this meal-plan account example, the obstacle is: “Five sequential retention steps stand between request and confirmation.” Evidence should show whether the alternative remains usable and whether “End deliveries” reaches the represented state. Repeated friction can delay an intended exit and increase the chance of another billing cycle.
  • Obscured outcome: upcomingReview prompt: How many steps, waits and channel changes separate “See another offer” from the completed meal-plan account outcome?
Neutral alternative
  • One optional alternative sits beside a direct confirmation action.Fairer design: Keep optional save offers non-blocking and provide a stable direct path to confirmation.
  • Request recorded: End deliveriesReview prompt: Count steps, waits, offers and channel changes through final confirmation; where does the route meet “The route is difficult to find, non-straightforward or includes steps beyond those reasonably necessary”?
Review questions (3)
  • How many steps, waits and channel changes separate “See another offer” from the completed meal-plan account outcome?
  • Count steps, waits, offers and channel changes through final confirmation; where does the route meet “The route is difficult to find, non-straightforward or includes steps beyond those reasonably necessary”?
  • Measure the same task through the clearest available route: does the effort difference persist once “mandatory consequence disclosure that does not impede completion” is accounted for?
Side-by-side meal-plan account interface showing “Before you go” and the clearer alternative “Confirm cancellation”.Provenance: Original hypothetical meal-plan account example created for this library; no real business, product or interface is depicted.
Open this example on its own page

What is a fairer alternative?

Provide an easy-to-find, direct exit path with only necessary verification and clear completion confirmation.

Verified enforcement context

These are real matters identified from regulator or court records. Their stated posture and existing legal basis must not be relabelled as enforcement of provisions that commence in 2027.

Enforcement example · Microsoft 365 subscription proceedings

The ACCC alleged that a lower-cost option was disclosed only during cancellation. Procedural posture: Proceedings and allegations only in the reviewed source; no liability finding should be implied.

Why it is included: This is verified current-ACL context, not enforcement of provisions commencing in 2027.

Microsoft in court for allegedly misleading millions of Australians over Microsoft 365 subscriptions

Enforcement example · HelloFresh and Youfoodz subscription proceedings

The ACCC alleged subscription sign-up and cancellation conduct under existing law. Procedural posture: Proceedings and allegations only in the reviewed source; no liability finding should be implied.

Why it is included: This is verified current-ACL context, not enforcement of provisions commencing in 2027.

HelloFresh and Youfoodz in court over alleged subscription traps

Context matters

Context and boundary cases

  • The user is trying to terminate or opt out of an existing relationship.
  • The route is difficult to find, non-straightforward or includes steps beyond those reasonably necessary.
  • Completion is verified through the resulting account or subscription state.
  • Boundary to test: Reasonable authentication and fraud controls
  • Boundary to test: mandatory consequence disclosure that does not impede completion
  • Boundary to test: declining an offer before enrolment
  • Does the contract meet the section 48B subscription definition and section 48G consumer or small-business requirement?
  • Can the exit control be found from normal account navigation and search?
  • How many steps are required compared with entry?
  • Which ending function or subscriber interest does each step protect, and why is that step reasonably necessary?
  • Is an online exit supplied whenever either statutory online trigger applies?
  • Do save offers delay, obscure or reverse the requested cancellation?
  • Can a person using assistive technology complete the exit?

When a similar design can serve a legitimate purpose

  • Reasonable authentication and fraud controls
  • mandatory consequence disclosure that does not impede completion
  • declining an offer before enrolment

Operational review

What teams should review

Teams
  • Product
  • Design
  • Engineering
  • Customer Support
  • Retention
  • Billing
  • Legal
  • Security
  1. How many steps, waits and channel changes separate “Weekdays 9 to 16 only” from the completed streaming subscription outcome?
  2. Count steps, waits, offers and channel changes through final confirmation; where does the route meet “The user is trying to terminate or opt out of an existing relationship”?
  3. Measure the same task through the clearest available route: does the effort difference persist once “Reasonable authentication and fraud controls” is accounted for?
  4. How many steps, waits and channel changes separate “See another offer” from the completed meal-plan account outcome?
  5. Count steps, waits, offers and channel changes through final confirmation; where does the route meet “The route is difficult to find, non-straightforward or includes steps beyond those reasonably necessary”?
  6. Measure the same task through the clearest available route: does the effort difference persist once “mandatory consequence disclosure that does not impede completion” is accounted for?
  7. Can a subscriber locate cancellation without an external search or support contact?
  8. Does either online-entry trigger apply to this kind of subscription?
  9. What purpose supports every screen, field and channel switch?
  10. Does accepting or declining a save offer preserve the cancellation request?
  11. Is cancellation complete before any avoidable additional billing event?
  12. Are the exit, end date and final charge confirmed durably?
  13. Have prescribed exceptions been rechecked?

Evidence to retain

  • 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

Legal map and implementation tools

Read the section 48F cancellation guideUse the readiness plannerCheck the Australian FAQ

Evidence base

Sources

  1. Dark commercial patternsOrganisation for Economic Co-operation and Development · Secondary · checked 2026-09-14 · OECD Digital Economy Papers No. 336
  2. Competition and Consumer Amendment (Unfair Trading Practices) Act 2026Federal Register of Legislation · Primary · checked 2026-09-14 · C2026A00064
  3. Competition and Consumer Act 2010, including Schedule 2: Australian Consumer LawFederal Register of Legislation · Primary · checked 2026-09-14 · C2004A00109
  4. Microsoft in court for allegedly misleading millions of Australians over Microsoft 365 subscriptionsAustralian Competition and Consumer Commission · Primary · checked 2026-09-14
  5. HelloFresh and Youfoodz in court over alleged subscription trapsAustralian Competition and Consumer Commission · Primary · checked 2026-09-14
  6. 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
  7. Unfair trading tricks and traps to be bannedTreasury Ministers · Primary · checked 2026-09-14
  8. Inquiry into the Competition and Consumer Amendment (Unfair Trading Practices) Bill 2026Senate Economics Legislation Committee · Primary · checked 2026-08-09