Sneaking · Australia

Drip pricing and mandatory fees

From 1 July 2027, section 48A will require specified information about a transaction-based charge to appear legibly, prominently, unambiguously and close to a displayed base price for consumer-type goods or services. It does not replace the ACL's single-price or misleading- conduct rules. Whether an amount is a transaction-based charge or an excluded amount must be checked carefully.

Commences 1 July 2027
Family
Sneaking
Also known as
  • hidden charges
  • drip pricing
  • late mandatory fee
  • transaction fee shown late
  • mandatory service charge absent from initial price
  • base price excludes unavoidable component
  • per-transaction fee unclear
  • hidden mandatory fee
  • transaction fee
  • service fee
  • unavoidable charge
  • Hidden costs or drip pricing
Journey stages
See visual examplesBrowse all unfair trading practices

Definition

What is this pattern?

A mandatory or foreseeable charge is omitted, obscured or revealed only after the user has invested effort in the transaction. 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

A mandatory or foreseeable charge is omitted, obscured or revealed only after the user has invested effort in the transaction. A foreseeable compulsory charge is withheld until later effort has been invested, making the offer appear cheaper at search, selection or comparison.

Warning signs

  • A price is displayed before a later charge becomes visible.
  • The charge is mandatory, transaction-linked or reasonably foreseeable for the selected path.
  • Earlier presentation does not effectively communicate amount, method or inclusion status.

Potential harms

  • Late disclosure can make the offer appear cheaper and exploit effort already invested in checkout.
  • Travellers may compare and select rooms using an understated unavoidable cost.

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 · Mandatory service fee revealed after payment details

A fictional booking site shows a $40 ticket through search and selection but adds a compulsory $9 service fee only after card details are entered.

Potential consumer harm: Late disclosure can make the offer appear cheaper and exploit effort already invested in checkout.

Illustrative example 2 · Resort fee appears after room selection

A fictional hotel result advertises $120 per night while a compulsory $28 nightly facility fee appears only in the final booking summary.

Potential consumer harm: Travellers may compare and select rooms using an understated unavoidable cost.

Illustrative example 3 · Mandatory booking charge shown only at payment

A booking site displays a $40 base price on search and product pages, but every transaction attracts a $9 booking charge revealed only after the consumer enters payment details.

Potential consumer harm: From commencement, the charge information may need to accompany each displayed base price under section 48A. Existing component-pricing and misleading-conduct rules also require review.

Illustrative example 4 · Variable service fee without a calculation method

A delivery marketplace shows meal prices but says only 'service fee may apply', although the compulsory fee is calculated as 8% of the basket.

Potential consumer harm: The statement omits the amount or method and may not satisfy the specific content and clarity requirements from 1 July 2027.

Ticket bookingCheckout

Mandatory service fee revealed after payment details

A fictional booking site shows a $40 ticket through search and selection but adds a compulsory $9 service fee only after card details are entered.

Potentially problematicTicket · $40
Neutral alternativeTicket total · $49

Why the first version can mislead: The final commercial state diverges from the choice represented earlier in the journey. The problematic state records: “A mandatory $9 service fee appears only after card entry.” Review the timing and affirmative selection needed before “Continue to payment” changes price, product or recurring liability. Late disclosure can make the offer appear cheaper and exploit effort already invested in checkout.

What a fairer design does: Show the foreseeable payable total and compulsory fee near the first material price and preserve it throughout the journey.

Show annotated differences (4)
Potentially problematic version
  • A mandatory $9 service fee appears only after card entry.Why this state matters: The final commercial state diverges from the choice represented earlier in the journey. The problematic state records: “A mandatory $9 service fee appears only after card entry.” Review the timing and affirmative selection needed before “Continue to payment” changes price, product or recurring liability. Late disclosure can make the offer appear cheaper and exploit effort already invested in checkout.
  • Pay $49Review prompt: Which affirmative action authorises “Continue to payment”, and where is the resulting price, product or recurring state shown before commitment?
Neutral alternative
  • The $40 base amount and $9 compulsory service fee appear together.Fairer design: Show the foreseeable payable total and compulsory fee near the first material price and preserve it throughout the journey.
  • Payable total and selected items, expanded: The summary shows the line items and total before “Pay $49” is activated.Review prompt: Compare the basket before and after the action, including total and line items; does the mutation satisfy “A price is displayed before a later charge becomes visible”?
Review questions (3)
  • Which affirmative action authorises “Continue to payment”, and where is the resulting price, product or recurring state shown before commitment?
  • Compare the basket before and after the action, including total and line items; does the mutation satisfy “A price is displayed before a later charge becomes visible”?
  • Which specific affirmative event creates the final commercial state, and could “Optional add-on deliberately selected” explain the observed outcome instead?
Side-by-side ticket booking interface showing “Ticket · $40” and the clearer alternative “Ticket total · $49”.Provenance: Original hypothetical ticket booking example created for this library; no real business, product or interface is depicted.
Open this example on its own page
Accommodation bookingPricing

Resort fee appears after room selection

A fictional hotel result advertises $120 per night while a compulsory $28 nightly facility fee appears only in the final booking summary.

Potentially problematicRoom · $120/night
Neutral alternativeRoom total · $148/night

Why the first version can mislead: The final commercial state diverges from the choice represented earlier in the journey. The problematic state records: “The unavoidable $28 nightly fee is omitted from search and room cards.” Review the timing and affirmative selection needed before “Select room” changes price, product or recurring liability. Travellers may compare and select rooms using an understated unavoidable cost.

What a fairer design does: Include compulsory charges in the comparable total and explain any component breakdown before room selection.

Show annotated differences (4)
Potentially problematic version
  • The unavoidable $28 nightly fee is omitted from search and room cards.Why this state matters: The final commercial state diverges from the choice represented earlier in the journey. The problematic state records: “The unavoidable $28 nightly fee is omitted from search and room cards.” Review the timing and affirmative selection needed before “Select room” changes price, product or recurring liability. Travellers may compare and select rooms using an understated unavoidable cost.
  • Choose at $148/nightReview prompt: Which affirmative action authorises “Select room”, and where is the resulting price, product or recurring state shown before commitment?
Neutral alternative
  • The base price and compulsory facility fee are shown before selection.Fairer design: Include compulsory charges in the comparable total and explain any component breakdown before room selection.
  • Price, period and commitment, expanded: The price and material terms associated with “Choose at $148/night” remain beside this choice.Review prompt: Place the compared prices, billing periods and material terms on one evidence sheet; where does it support “The charge is mandatory, transaction-linked or reasonably foreseeable for the selected path”?
Review questions (3)
  • Which affirmative action authorises “Select room”, and where is the resulting price, product or recurring state shown before commitment?
  • Place the compared prices, billing periods and material terms on one evidence sheet; where does it support “The charge is mandatory, transaction-linked or reasonably foreseeable for the selected path”?
  • Which specific affirmative event creates the final commercial state, and could “variable charge impossible to calculate but calculation method and applicability clearly disclosed” explain the observed outcome instead?
Side-by-side accommodation booking interface showing “Room · $120/night” and the clearer alternative “Room total · $148/night”.Provenance: Original hypothetical accommodation booking 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?

Show unavoidable and transaction-linked charges with the price, including amount or method, applicability and inclusion status.

Context matters

Context and boundary cases

  • A price is displayed before a later charge becomes visible.
  • The charge is mandatory, transaction-linked or reasonably foreseeable for the selected path.
  • Earlier presentation does not effectively communicate amount, method or inclusion status.
  • Boundary to test: Optional add-on deliberately selected
  • Boundary to test: variable charge impossible to calculate but calculation method and applicability clearly disclosed
  • Boundary to test: government charge clearly disclosed at the initial price
  • Is the amount compulsory for the transaction or genuinely optional?
  • Is it a price for the good or service itself, or a separate charge associated with supply?
  • When is the amount payable relative to the base price?
  • Does an exclusion in section 48A(8), or a later regulation, apply?
  • Can the charge be calculated and shown as a single price under existing section 48?
  • Does every base-price placement carry the required nearby charge information?

When a similar design can serve a legitimate purpose

  • Optional add-on deliberately selected
  • variable charge impossible to calculate but calculation method and applicability clearly disclosed
  • government charge clearly disclosed at the initial price

Operational review

What teams should review

Teams
  • Pricing
  • Ecommerce
  • Product
  • Design
  • Engineering
  • Legal
  • Finance
  1. Which affirmative action authorises “Continue to payment”, and where is the resulting price, product or recurring state shown before commitment?
  2. Compare the basket before and after the action, including total and line items; does the mutation satisfy “A price is displayed before a later charge becomes visible”?
  3. Which specific affirmative event creates the final commercial state, and could “Optional add-on deliberately selected” explain the observed outcome instead?
  4. Which affirmative action authorises “Select room”, and where is the resulting price, product or recurring state shown before commitment?
  5. Place the compared prices, billing periods and material terms on one evidence sheet; where does it support “The charge is mandatory, transaction-linked or reasonably foreseeable for the selected path”?
  6. Which specific affirmative event creates the final commercial state, and could “variable charge impossible to calculate but calculation method and applicability clearly disclosed” explain the observed outcome instead?
  7. List every amount a consumer may pay: which are mandatory, optional, surcharges, government charges or pass-through amounts?
  8. Does the same base price appear in ads, search, structured data, comparison feeds or affiliates?
  9. Can the business display a single total price instead?
  10. If a fee varies, is the calculation method intelligible before checkout?
  11. Have mobile truncation and dynamically loaded prices been tested?
  12. Has the regulations check been repeated since the content review date?

Evidence to retain

  • 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

Legal map and implementation tools

Read the section 48A 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. Unfair trading tricks and traps to be bannedTreasury Ministers · Primary · checked 2026-09-14
  5. Inquiry into the Competition and Consumer Amendment (Unfair Trading Practices) Bill 2026Senate Economics Legislation Committee · Primary · checked 2026-08-09