Editorial implementation guidanceSneaking
Bait and switch
Bait and switch is a working label for this design mechanism: The user selects a represented action or offer but receives a materially different outcome that favours the business. 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.
2 visual examples
View examples and legal context: Bait and switch→Editorial implementation guidanceInterface interference
Bundled options
Bundled options is a working label for this design mechanism: Distinct products, services, permissions or purposes are grouped under one choice so the user cannot readily understand or select them separately. 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.
2 visual examples
View examples and legal context: Bundled options→Editorial implementation guidanceInterface interference
Complex or inaccessible language
Complex or inaccessible language is a working label for this design mechanism: Material guidance is presented in a language or level of complexity that makes informed choice materially harder for the target user. 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.
2 visual examples
View examples and legal context: Complex or inaccessible language→Commences 1 July 2027Interface interference
Confirmshaming and emotional pressure
Confirmshaming is design terminology, not a named offence in the final Act. Loaded language may nevertheless manipulate a consumer or contribute to unreasonable pressure or distortion under section 28B from 1 July 2027, where likely financial or other detriment also exists. Tone alone is not enough; placement, repetition, choice structure and consequence matter.
2 visual examples
View examples and legal context: Confirmshaming and emotional pressure→Commences 1 July 2027Urgency
Countdown timer
Countdown timer is a working label for this design mechanism: A visible countdown applies time pressure, particularly where it resets, is personalised without disclosure or has no corresponding consequence at zero. 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.
2 visual examples
View examples and legal context: Countdown timer→Commences 1 July 2027Sneaking
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.
2 visual examples
View examples and legal context: Drip pricing and mandatory fees→Editorial implementation guidanceInterface interference
Feedforward ambiguity
Feedforward ambiguity is a working label for this design mechanism: A control does not let the user reasonably predict its material outcome before activation. 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.
2 visual examples
View examples and legal context: Feedforward ambiguity→Editorial implementation guidanceForced action
Forced or bundled consent
Forced or bundled consent is a working label for this design mechanism: Access is conditioned on accepting optional or separable data uses, communications or permissions as one bundled choice. 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.
2 visual examples
View examples and legal context: Forced or bundled consent→Commences 1 July 2027Forced action
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.
2 visual examples
View examples and legal context: Forced registration→Editorial implementation guidanceObstruction
Intermediate currency
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.
2 visual examples
View examples and legal context: Intermediate currency→Editorial implementation guidanceUrgency
Limited-time or reservation claim
Limited-time or reservation claim is a working label for this design mechanism: A textual deadline or temporary-reservation claim pressures action, particularly where the deadline renews or its stated consequence does not occur. 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.
2 visual examples
View examples and legal context: Limited-time or reservation claim→Editorial implementation guidanceUrgency
Low-stock claim
Low-stock claim is a working label for this design mechanism: A claim that few units remain applies purchase pressure, especially where inventory basis or persistence is unsupported. 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.
2 visual examples
View examples and legal context: Low-stock claim→Editorial implementation guidanceObstruction
Obstructed alternative
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.
2 visual examples
View examples and legal context: Obstructed alternative→Commences 1 July 2027Interface interference
Preselection and biased defaults
The final Act does not prohibit every preselected option as a standalone category. A default can, however, contribute to manipulation or unreasonable distortion under section 28B where the complete test and likely detriment are present. Other rules can apply now, including price, misleading-conduct, consent or sector-specific requirements, depending on the option.
2 visual examples
View examples and legal context: Preselection and biased defaults→Editorial implementation guidanceInterface interference
Pressured upselling
Pressured upselling is a working label for this design mechanism: A more expensive or profitable option is made the practical focal choice through preselection, visual prominence or obscured lower-cost alternatives. 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.
2 visual examples
View examples and legal context: Pressured upselling→Editorial implementation guidanceNagging
Repeated prompting
Repeated prompting is a working label for this design mechanism: A business-favoured request repeatedly interrupts the user after decline, dismissal or non-response without a durable way to stop 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.
2 visual examples
View examples and legal context: Repeated prompting→Editorial implementation guidanceSneaking
Sneak into basket
Sneak into basket is a working label for this design mechanism: A paid or consequential item is added to a basket or transaction without a clear, deliberate and specific user choice. 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.
2 visual examples
View examples and legal context: Sneak into basket→Commences 1 July 2027Sneaking
Subscription traps and automatic renewal
The Act creates specific subscription rules from 1 July 2027. Section 48D requires clear pre-contract disclosure of subscription status, payment liabilities, duration, continuation, notice and exit information. Section 48E's in-contract information duty applies only as prescribed, so the Act does not yet supply a universal reminder interval. Existing ACL rules already apply to misleading recurring-price and subscription representations.
2 visual examples
View examples and legal context: Subscription traps and automatic renewal→