Starts 1 July 2027/C2026A00064/Read from the authorised Act/Not legal advice; does not certify
Competition and Consumer CheckerThe Act, section by section
Section 48D(4)Scope or machinery

The six matters to disclose

The information must cover the liabilities the consumer would or may incur, the period of the contract, renewal or extension, any notice required before the consumer can end it, how the consumer can end it, and any matter prescribed by regulation. Five matters are listed in the Act and the sixth is a regulation power, so the count can grow.

Competition and Consumer Amendment (Unfair Trading Practices) Act 2026, Schedule 1, Part 3, item 20, section 48D(4)Starts 1 July 2027Part 3: subscription contracts
The requirement

Disclose every listed matter for the offer. The five substantive matters are cumulative, and paragraph (4)(f) lets a regulation add more. A generic "terms apply" line does not disclose any of them.

Who it binds. The supplier making the offer, and the content, pricing and legal teams that supply the facts.

Operative term. how a party to the contract (other than the supplier) can end the contract

What this means in practice

The six matters are the facts a consumer needs to avoid a trap. Liabilities include the first payment, the recurring payment, any fee that may apply and any price rise. The period is the initial term and what happens after it. Renewal covers automatic renewal, extension and any other continuation. Notice is what the consumer must do before ending, including a notice period. The exit method is the practical route: a link, a form, a phone number, a store. The sixth item is open, so the regulations can add matters. Build the disclosure from the contract data, not from a marketing summary, so the price and the period match the terms. Put the matrix beside the agree control, so the six matters are visible before the commitment.

How to test it

Compare the disclosure with the signed contract line by line. For each of the six matters, point to the clause and the sentence in the offer that discloses it. If the offer says "cancel anytime" but the contract requires 30 days notice, the disclosure is wrong. If the offer shows a monthly price but not the minimum term, the period is missing. Test a price rise, a free trial and a discounted first period, because those are the cases where the six matters change.

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.

  • Disclosure matrixA row for each of the six matters, the contract clause and the offer wording.
  • Contract data feedThe source of the price, period, renewal and notice facts used in the offer.
  • Price rise testThe disclosure for a contract that moves to a higher rate, including the date and amount.
  • Notice wordingThe exact notice the consumer must give, and where it is disclosed.
  • Legal reviewThe review that confirms the disclosure matches the contract.

What to do first

  1. Build a six-row disclosure matrix for every subscription product.
  2. Take the facts from the contract, not from the campaign brief.
  3. Re-test the matrix when a price, term or notice period changes.

Questions

Are the six matters a minimum?
Yes. Paragraph (4)(f) allows a matter to be prescribed, so the list can grow. All six listed matters must be disclosed.
Does "cancel anytime" satisfy the exit disclosure?
It is unlikely to. The Act requires how the consumer can end the contract, and any notice required. A slogan does not show the route or the notice period.

Related sections

s 48D(2): Offer disclosures 48B: Subscription tests 48F(1): Exit method