Forced action · Australia
Forced registration
Forced registration is a working label for this design mechanism: The user must create an account, or is led to believe one is required, to complete a goal that could plausibly be provided without it. 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.
- Family
- Forced action
- Also known as
- Journey stages
Definition
What is this pattern?
The user must create an account, or is led to believe one is required, to complete a goal that could plausibly be provided without it. 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
The user must create an account, or is led to believe one is required, to complete a goal that could plausibly be provided without it. The gate converts an otherwise available task into account creation, so the user must create a persistent identity record before reaching the requested outcome.
Warning signs
- A desired goal is gated by account creation.
- No equivalent guest or bypass route is available or discoverable.
- Registration is not evidently necessary for the specific function.
Potential harms
- A shopper may surrender unnecessary information or abandon a purchase after investing time in the basket.
- People cannot compare the offer without creating an identity record and may receive communications they did not seek.
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 · Account wall at guest checkout
A fictional retailer removes guest checkout after an item is added and requires a full account, date of birth and saved password before payment can continue.
Potential consumer harm: A shopper may surrender unnecessary information or abandon a purchase after investing time in the basket.
Illustrative example 2 · Profile required before price estimate
A fictional repair service asks visitors to create a profile and verify a phone number before it reveals even an indicative service price.
Potential consumer harm: People cannot compare the offer without creating an identity record and may receive communications they did not seek.
Account wall at guest checkout
A fictional retailer removes guest checkout after an item is added and requires a full account, date of birth and saved password before payment can continue.
Create an account to continue. No guest route is shown after the basket has been prepared.. Email address: Enter email address. Date of birth: Enter date of birth. Password: Enter password. Register and save my details
Choose how to check out. Guest checkout and optional account creation are presented together.. Delivery email: Enter delivery email. Continue as guest. Purpose and refusal effect, expanded: The form explains why “Continue as guest” is requested and what happens if it is not used.
Why the first version can mislead: The additional dependency controls access to the checkout goal. The panel states: “No guest route is shown after the basket has been prepared.” Reviewers need to establish whether “Register and save my details” is necessary for the selected task or pressures the user into a separable action. A shopper may surrender unnecessary information or abandon a purchase after investing time in the basket.
What a fairer design does: Keep a clearly labelled guest route beside account creation and request only delivery and payment data needed for the order.
Show annotated differences (4)
- No guest route is shown after the basket has been prepared.Why this state matters: The additional dependency controls access to the checkout goal. The panel states: “No guest route is shown after the basket has been prepared.” Reviewers need to establish whether “Register and save my details” is necessary for the selected task or pressures the user into a separable action. A shopper may surrender unnecessary information or abandon a purchase after investing time in the basket.
- Register and save my detailsReview prompt: What functional need makes “Register and save my details” necessary for the online retail checkout goal, and can that need be met with less disclosure or commitment?
- Guest checkout and optional account creation are presented together.Fairer design: Keep a clearly labelled guest route beside account creation and request only delivery and payment data needed for the order.
- Purpose and refusal effect, expanded: The form explains why “Continue as guest” is requested and what happens if it is not used.Review prompt: Which fields or permissions are required, what happens on refusal, and does the resulting state support this criterion: “A desired goal is gated by account creation”?
Review questions (3)
- What functional need makes “Register and save my details” necessary for the online retail checkout goal, and can that need be met with less disclosure or commitment?
- Which fields or permissions are required, what happens on refusal, and does the resulting state support this criterion: “A desired goal is gated by account creation”?
- Could the stated purpose make this dependency genuinely necessary under the boundary “Account creation that is inherently necessary for persistent account functionality”, and what product evidence would demonstrate that necessity?
Profile required before price estimate
A fictional repair service asks visitors to create a profile and verify a phone number before it reveals even an indicative service price.
Unlock your estimate. Name, phone, birth date and password are required before any price appears.. Full name: Enter full name. Mobile number: Enter mobile number. Date of birth: Enter date of birth. Password: Enter password. Create profile
Estimated service price. The indicative range and assumptions appear before optional saving or booking.. Service postcode: Enter service postcode. View estimate without an account. Purpose and refusal effect, expanded: The form explains why “View estimate without an account” is requested and what happens if it is not used.
Why the first version can mislead: The additional dependency controls access to the pricing goal. The panel states: “Name, phone, birth date and password are required before any price appears.” Reviewers need to establish whether “Create profile” is necessary for the selected task or pressures the user into a separable action. People cannot compare the offer without creating an identity record and may receive communications they did not seek.
What a fairer design does: Show the estimate and its assumptions first, then offer account creation only when it is needed to book or save the quote.
Show annotated differences (4)
- Name, phone, birth date and password are required before any price appears.Why this state matters: The additional dependency controls access to the pricing goal. The panel states: “Name, phone, birth date and password are required before any price appears.” Reviewers need to establish whether “Create profile” is necessary for the selected task or pressures the user into a separable action. People cannot compare the offer without creating an identity record and may receive communications they did not seek.
- Create profileReview prompt: What functional need makes “Create profile” necessary for the home-services quote goal, and can that need be met with less disclosure or commitment?
- The indicative range and assumptions appear before optional saving or booking.Fairer design: Show the estimate and its assumptions first, then offer account creation only when it is needed to book or save the quote.
- Purpose and refusal effect, expanded: The form explains why “View estimate without an account” is requested and what happens if it is not used.Review prompt: Which fields or permissions are required, what happens on refusal, and does the resulting state support this criterion: “No equivalent guest or bypass route is available or discoverable”?
Review questions (3)
- What functional need makes “Create profile” necessary for the home-services quote goal, and can that need be met with less disclosure or commitment?
- Which fields or permissions are required, what happens on refusal, and does the resulting state support this criterion: “No equivalent guest or bypass route is available or discoverable”?
- Could the stated purpose make this dependency genuinely necessary under the boundary “legally or operationally necessary identity verification with clear explanation”, and what product evidence would demonstrate that necessity?
What is a fairer alternative?
Provide a clearly visible guest or no-account path unless registration is genuinely necessary, and explain necessity before collecting data.
Legal and information status
How Australian law may apply
The user must create an account, or is led to believe one is required, to complete a goal that could plausibly be provided without it. The gate converts an otherwise available task into account creation, so the user must create a persistent identity record before reaching the requested outcome. Apply section 28B(2) to the whole journey. Section 28B(6)(d)'s obstruction example may be relevant where a gate makes a decision or its fulfilment disproportionately difficult. The Act does not say that every registration requirement is unreasonable or unnecessary. Existing misleading-conduct, privacy and sector-specific rules may apply depending on the representation and data involved; this record does not determine those regimes. No final ACCC section 28B guidance addressing account walls had been identified by the review date.
ACL section 28B(2), inserted by the 2026 Act
Possible risk indicator
Potentially applies when the gate forms part of manipulative or unreasonably distorting conduct and likely detriment results.
ACL section 28B(6)(d), inserted by the 2026 Act
Possible risk indicator
Offers a non-exhaustive example involving unreasonable obstruction of making or fulfilling a decision.
Evidence layers and open questions
Applicable law, enforcement records, policy preparation, stakeholder input, editorial analysis and unknown future details remain visibly distinct.
Final Act mappingCommences 1 July 2027
This editorial practice label is not itself an express statutory prohibition. Apply the complete provision and its scope to the facts.
Possible general-test applicationCommences 1 July 2027
ACL section 28B(2), inserted by the 2026 Act: Potentially applies when the gate forms part of manipulative or unreasonably distorting conduct and likely detriment results. ACL section 28B(6)(d), inserted by the 2026 Act: Offers a non-exhaustive example involving unreasonable obstruction of making or fulfilling a decision.
Existing ACLCurrent enforcement
Existing ACL provisions continue to apply on their own elements before and after commencement. The 2027 provisions must not be applied early.
Verified enforcement contextCurrent enforcement
No named pattern-specific enforcement example is asserted on this page. Existing ACL analysis remains fact-specific and separate from the 2027 provisions.
RegulationsRegulation pending
Later regulations may affect specified exclusions, matters or exceptions. That uncertainty does not postpone a core enacted rule unless the provision itself depends on prescription.
Regulator implementation materialGuidance pending
Government funding and parliamentary material anticipate regulator education and guidance. No dedicated final ACCC implementation guide is treated here as published.
Journey and evidence recommendationsEditorial implementation guidance
Provide a clearly visible guest or no-account path unless registration is genuinely necessary, and explain necessity before collecting data. This is editorial portal guidance, not a statutory duty, regulator safe harbour or compliance certificate.
Context matters
Context and boundary cases
- A desired goal is gated by account creation.
- No equivalent guest or bypass route is available or discoverable.
- Registration is not evidently necessary for the specific function.
- Boundary to test: Account creation that is inherently necessary for persistent account functionality
- Boundary to test: legally or operationally necessary identity verification with clear explanation
- Why is an account or each requested field operationally necessary?
- Can the transaction be completed as a guest?
- Is the gate imposed before the consumer can see price or material terms?
- Does a registration step enrol the consumer in anything beyond the requested transaction?
- Can support, returns or cancellation be accessed without creating a new account?
- What non-financial detriment or abandoned effort could result?
When a similar design can serve a legitimate purpose
- Account creation that is inherently necessary for persistent account functionality
- legally or operationally necessary identity verification with clear explanation
Operational review
What teams should review
- Teams
- What functional need makes “Register and save my details” necessary for the online retail checkout goal, and can that need be met with less disclosure or commitment?
- Which fields or permissions are required, what happens on refusal, and does the resulting state support this criterion: “A desired goal is gated by account creation”?
- Could the stated purpose make this dependency genuinely necessary under the boundary “Account creation that is inherently necessary for persistent account functionality”, and what product evidence would demonstrate that necessity?
- What functional need makes “Create profile” necessary for the home-services quote goal, and can that need be met with less disclosure or commitment?
- Which fields or permissions are required, what happens on refusal, and does the resulting state support this criterion: “No equivalent guest or bypass route is available or discoverable”?
- Could the stated purpose make this dependency genuinely necessary under the boundary “legally or operationally necessary identity verification with clear explanation”, and what product evidence would demonstrate that necessity?
- Can the operational owner explain why every required field is needed at this exact stage?
- What material information is unavailable until after registration?
- Are marketing choices genuinely optional and separate?
- Can a guest purchaser obtain support, return or cancel without creating an account?
- Does the same outcome require fewer steps through another channel?
Evidence to retain
- field-by-field necessity register
- journey map for guest and account users
- consent and copy approvals
- data-flow diagram and retention decision
- support and cancellation test scripts
- abandonment and complaint analysis
- 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
Evidence base
Sources
- Dark commercial patternsOrganisation for Economic Co-operation and Development · Secondary · checked 2026-09-14 · OECD Digital Economy Papers No. 336
- 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
- Unfair trading tricks and traps to be bannedTreasury Ministers · Primary · checked 2026-09-14
- Inquiry into the Competition and Consumer Amendment (Unfair Trading Practices) Bill 2026Senate Economics Legislation Committee · Primary · checked 2026-08-09