Use 1 July 2027 as the start date for the Act. The table relates only to the Act as originally enacted, so a later amendment is dealt with separately.
Who it binds. Every supplier, adviser and reviewer planning for the new rules.
Operative term. 1 July 2027
What this means in practice
A single start date makes the planning simple, but it compresses the work. The Act was assented to on 6 July 2026, so there is a lead time of almost a year. The subscription provisions need contract and flow changes, the drip pricing duty needs a checkout change, and the general ban needs a conduct review. All three have to be ready for the same day. The commencement table is the source for the date; the page cites it and does not treat a later instrument as changing it. Build the plan backwards from 1 July 2027, with a freeze and a test window before the date.
How to test it
Put 1 July 2027 in the plan as the first day the duties apply. For conduct, the date of the conduct matters. For contracts, the date of entry or the later renewal, extension, continuation or variation matters. Check the Act and any later amendment before relying on the date, and record the source. Do not use the assent date as the start date; it is not.
Evidence to keep
The Act does not prescribe these records. They are the artefacts our reading says a regulator or auditor may ask for; keep the ones that fit your business and the provision.
- Plan baselineThe dated plan with 1 July 2027 as the first day of the duties.
- Source noteThe commencement table and the date it was checked.
- Freeze dateThe date changes to pricing, contracts and exits are frozen before the start.
- Test windowThe period in which the new flows are tested before the start.
- Amendment checkThe check for any later amendment that changes the start or a duty.
What to do first
- Plan backwards from 1 July 2027, not from the assent date.
- Freeze the relevant flows before the start and test them in a window.
- Check for a later amendment before the date.