Adds unnecessary friction, barriers or dead ends to dissuade the user from a choice, right or task.
This family contains 8 canonical practicesand 16 paired fictional interface examples. It is a learning and review structure, not a statutory category, regulator finding or conclusion that a particular interface is unlawful.
Begin with observable interface states and sequences. These signals are prompts to preserve evidence and ask better questions; they are not a shortcut to the elements of an Australian legal test.
A consumer-favourable path takes more steps or channel changes than entry.
Controls loop, stall, lose progress or fail to reach the represented state.
Alternatives, support or comparison information are hidden behind avoidable barriers.
Fairer design
Principles for a more neutral choice
A fairer alternative should preserve the person’s intended task while making consequences, alternatives and changes of mind usable. It is a practical comparison, not a legal safe harbour.
Make rights, alternatives and exit routes findable from normal navigation.
Limit friction to steps needed for accuracy, security or the user’s interests.
Confirm completion with a durable state and an accessible recovery route.
Australian legal context
Apply the legal layer after identifying the mechanism
A taxonomy helps reviewers name and compare an interaction. Legal analysis still depends on the provision in force, the complete journey, the consumer context, evidence and the alleged detriment. Keep these layers separate in reports and release decisions.
Current law and enforcement
Existing ACL provisions, including misleading conduct and false-representation rules, may apply now where their own elements are satisfied. Do not describe current cases as enforcement of section 28B.
Enacted section 28B
From 1 July 2027, the general prohibition requires consumer-connected conduct that manipulates the consumer or unreasonably distorts the decision environment and causes, or is likely to cause, financial or other detriment. A family label alone satisfies none of those elements.
Regulations and guidance
Pending regulations or dedicated regulator guidance must be marked as pending until published and verified. They must not be silently converted into present duties, exclusions or regulator-approved design rules.
Editorial implementation guidance
Recognition signals, fair-design principles and evidence prompts on this page support product, design, engineering and legal review. They do not replace advice on a specific journey or certify compliance.
Review complete transitions rather than isolated screens. The same mechanism can change meaning when a person is comparing prices, confirming a purchase, managing an account or trying to leave a service.
Each guide provides a plain-language definition, inclusion and exclusion boundaries, at least two paired HTML examples, fairer alternatives, review questions, evidence prompts and a context-specific Australian legal-information map.
Editorial implementation guidanceObstruction
Account deletion obstruction
Account deletion obstruction is a working label for this design mechanism: Deleting an account is unavailable, disguised as another outcome or burdened by unnecessary barriers. This is editorial implementation guidance for Australian journeys, not a finding of unlawfulness. From 1 July 2027, a similar interface is relevant to ACL section 28B only if the complete consumer-connection, manipulation or unreasonable-distortion and actual-or-likely-detriment test is met. Current ACL rules require a separate assessment.
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.
Comparison prevention is a working label for this design mechanism: Information needed to compare products, plans or consequences is presented in inconsistent, fragmented or unusable form. This is editorial implementation guidance for Australian journeys, not a finding of unlawfulness. From 1 July 2027, a similar interface is relevant to ACL section 28B only if the complete consumer-connection, manipulation or unreasonable-distortion and actual-or-likely-detriment test is met. Current ACL rules require a separate assessment.
Customer-support obstruction is a working label for this design mechanism: Access to support needed to resolve a purchase, account, charge or right is hidden or burdened by unnecessary loops and dead ends. This is editorial implementation guidance for Australian journeys, not a finding of unlawfulness. From 1 July 2027, a similar interface is relevant to ACL section 28B only if the complete consumer-connection, manipulation or unreasonable-distortion and actual-or-likely-detriment test is met. Current ACL rules require a separate assessment.
Dead end is a working label for this design mechanism: A consumer-favourable route cannot reach its represented outcome and instead loops, stalls or loses progress. This is editorial implementation guidance for Australian journeys, not a finding of unlawfulness. From 1 July 2027, a similar interface is relevant to ACL section 28B only if the complete consumer-connection, manipulation or unreasonable-distortion and actual-or-likely-detriment test is met. Current ACL rules require a separate assessment.
Intermediate currency is a working label for this design mechanism: A proprietary currency makes the real monetary cost or remaining value unnecessarily hard to understand. This is editorial implementation guidance for Australian journeys, not a finding of unlawfulness. From 1 July 2027, a similar interface is relevant to ACL section 28B only if the complete consumer-connection, manipulation or unreasonable-distortion and actual-or-likely-detriment test is met. Current ACL rules require a separate assessment.
Obstructed alternative is a working label for this design mechanism: A relevant alternative within the current decision is hidden, blocked or made materially harder than the business-favoured action. This is editorial implementation guidance for Australian journeys, not a finding of unlawfulness. From 1 July 2027, a similar interface is relevant to ACL section 28B only if the complete consumer-connection, manipulation or unreasonable-distortion and actual-or-likely-detriment test is met. Current ACL rules require a separate assessment.
Privacy maze is a working label for this design mechanism: Privacy controls are fragmented, inconsistently labelled or layered so that limiting collection or use is unnecessarily difficult. This is editorial implementation guidance for Australian journeys, not a finding of unlawfulness. From 1 July 2027, a similar interface is relevant to ACL section 28B only if the complete consumer-connection, manipulation or unreasonable-distortion and actual-or-likely-detriment test is met. Current ACL rules require a separate assessment.
