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 48F(1)Held as a control

An exit that is easy to find and use

A supplier under a subscription contract that meets the consumer or small business requirement must provide a way to end it. Every route must be easy to find, straightforward, and require only steps that are needed to end it and to protect the subscriber. If the subscriber entered online, or online entry is offered, one route must be online.

Competition and Consumer Amendment (Unfair Trading Practices) Act 2026, Schedule 1, Part 3, item 20, section 48F(1) and (2)Starts 1 July 2027Part 3: subscription contracts
The requirement

Provide at least one exit route, make every route easy to find and straightforward, and keep the steps to what is needed. Add an online route where the contract was entered online or online entry is offered for the same sort of product.

Who it binds. A supplier of a subscription contract that meets the consumer requirement or the small business requirement.

Operative term. easy to find

What this means in practice

This is the provision that answers the subscription trap. The test is not whether a cancellation route exists, but whether a subscriber can find it and use it without a queue, a script or a retention maze. Every route counts, so a phone line that is hard to find is still a route that fails the standard. The online route is required where the subscriber entered online or the supplier offers online entry for the same sort of product, which covers most consumer subscriptions. The steps must be needed to end it and to protect the subscriber, so a confirmation and an identity check can be reasonable, but a required sales call usually is not.

How to test it

Start from the subscriber account, not from the help centre. Time how long it takes to find the exit and complete it. Count the steps and ask whether each one is necessary to end the contract or protect the subscriber. Try the route on a phone and while signed out. If the subscriber entered online, confirm that an online route exists. Record the route, the steps, the time and the screens. Repeat after any redesign, because a single extra screen can turn a straightforward exit into an obstruction.

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.

  • Exit route mapEvery route to end the contract, with the entry point, the steps and the time to complete.
  • Online route proofA recording of the online exit for a contract entered online or offered online.
  • Step justificationThe reason each step is necessary to end the contract or protect the subscriber.
  • Retention checkThe offers, saves or delays shown during exit, and why they do not obstruct.
  • Phone testThe time to reach a person and complete the exit by phone, with the date.

What to do first

  1. Put the exit in the account area, not only in a help article.
  2. Count the steps and remove any that are not necessary to end the contract.
  3. Record the online exit on a phone and keep the recording with the release.

Questions

Does a phone-only exit comply?
Not where the subscriber entered online, or where the supplier offers online entry for the same sort of product. Section 48F(1)(c) requires one online route in those cases.
Can a supplier ask why the subscriber is leaving?
It can ask. It cannot make the answer a condition of ending the contract, because the steps must be needed to end it and to protect the subscriber.

Related sections

s 48B: Subscription tests 48D(4): Six matterss 28B(6): Examples