Sapna is a content writer at Sprintlaw. She has completed a Bachelor of Laws with a Bachelor of Arts. Since graduating, she has worked primarily in the field of legal research and writing, and now helps Sprintlaw assist small businesses.
How To Set Up Pricing Processes That Comply (Step-By-Step)
- 1) Map Every Possible Cost In The Customer Journey
- 2) Configure Your Website And POS To Display A Single Price
- 3) Be Upfront About Delivery
- 4) Build A Promotions Checklist
- 5) Train Your Team
- 6) Keep Consistent Legal Policies On Your Site
- 7) Honour Mistakes Quickly And Record Your Fix
- 8) Sense-Check Claims With A Consumer Lens
- What Legal Documents Will Help You Manage Pricing And Promotions?
- Key Takeaways
Clear, honest pricing builds trust. It also keeps you on the right side of Australian consumer law when you advertise prices for your products online, in-store or in marketing campaigns.
If you’re selling goods in Australia, you’re required to present prices accurately and avoid tactics that could mislead customers - even unintentionally. From GST and “drip pricing” to “was/now” discounts and recommended retail prices, there are a few rules to get right before you hit “publish”.
In this guide, we’ll walk through what the law expects, common pitfalls to avoid, and practical steps to set up pricing processes that keep you compliant while still allowing smart promotions. We’ll also flag the key legal documents that support your pricing strategy.
What Does Australian Law Require When You Advertise Prices?
Australian pricing rules sit under the Australian Consumer Law (ACL). The core idea is simple: don’t mislead or deceive customers about the price of your goods, and make sure any unavoidable fees are included in the headline price where required.
If you want a deeper primer on the basics, have a look at our overview of advertised price laws.
The General Prohibition On Misleading Conduct
Pricing must not be misleading or deceptive. This broad rule comes from Section 18 of the ACL. It covers things like hidden fees, confusing disclaimers, or promotions that create the wrong impression about what a customer will actually pay.
False Or Misleading Price Representations
It’s also unlawful to make specific false or misleading statements about price under Section 29. This includes “was/now” comparisons that aren’t genuine, “limited time” claims that never end, or saying stock is discounted when it wasn’t sold at the higher price for a reasonable period.
Component Pricing (Single Price Rule)
If you advertise or display a price that consists of several components, you generally need to also display a single price that includes the total of all mandatory costs (for example, GST and compulsory handling fees). This is often called the “single price” rule and is a common area where businesses trip up with “drip pricing”. We cover the practicalities in more detail below.
Multiple Pricing
If the same item is displayed with two different prices (say, a shelf ticket and a barcode), you usually need to sell it for the lower price. This is why robust ticketing and POS checks matter, especially during catalogue changeovers or major sales events.
Recommended Retail Prices (RRPs)
You can refer to RRPs, but you must do so accurately. If you say “RRP $149, our price $119”, make sure that RRP is genuine and current - otherwise you risk misleading customers. For a quick refresher on fair use of RRPs and similar comparisons, see our guide on RRPs vs MSRP.
Unit Pricing
Some grocery and supermarket items must show a unit price (like $/100g or $/L) so customers can compare value. If your goods fall into those categories, ensure your shelf labels, online product pages and catalogues display unit pricing correctly and consistently.
Component Pricing, Surcharges And “Drip Pricing”: What Must Be Included?
This is the area that catches many retailers out - especially online. The rule of thumb is that if a fee is unavoidable for most customers, it should be made part of the single price you display as the main price.
GST And Mandatory Fees
Your headline price should generally include GST and any mandatory fees that apply to most customers. For example, if a $10 “handling fee” always applies at checkout, that fee should be included in the main price you advertise, not added at the last moment.
Delivery And Optional Extras
Delivery can be shown separately if it genuinely varies by location or shipping method, but you should still be transparent early in the purchase journey. If you promote “from $49 + delivery”, make sure delivery estimates or calculators are easy to find, and don’t hide expensive default options deep in the checkout.
Payment Surcharges
Card surcharges must be reasonable and cost-based. If you apply a surcharge, disclose it clearly before payment. If you restrict certain payments or rely on cash-only policies for some transactions, be mindful of the rules and customer expectations around whether a business may refuse cash payments.
Drip Pricing (Avoid Hidden Add-Ons)
Drip pricing is where you reveal extra fees late in the checkout (booking fees, service fees, compulsory insurance) so the final price is much higher than the advertised price. This practice can mislead customers. If a fee is unavoidable, include it in the upfront single price and keep any remaining optional extras truly optional and clearly labelled.
Common Pricing Practices That Get Businesses Into Trouble
Sales and promos are powerful, but a few tactics regularly attract complaints and enforcement. Here’s what to watch for.
“Was/Now” Or Strike-Through Pricing
If you say “Was $199, now $119”, the “was” price should be genuine - meaning you actually sold a reasonable volume of the same item at $199 for a meaningful period before the sale. If the higher price was used only briefly or rarely, the comparison may mislead customers.
Comparative Claims And RRPs
“Save $50 off RRP” is risky if the RRP is outdated or artificial. Ensure your comparisons are based on accurate, current information and avoid inflated benchmarks. If your market doesn’t commonly use RRPs for the product, consider whether that comparison helps or confuses customers.
“Free” Offers With Hidden Conditions
If something is “free”, don’t build the cost back in elsewhere. You can require a genuine purchase to get a free bonus, but ensure any conditions are clearly disclosed upfront (like minimum spend, specific products, or the exact value of the free item). Small-print surprises won’t pass the truth-in-advertising test.
Bait Advertising (Limited Stock Promos)
Promoting a sharp price with minimal stock - just to draw people in - can be considered bait advertising. If supply is genuinely limited, say so clearly and ensure you’ve stocked a reasonable quantity for the campaign. Have rainchecks or fair alternatives ready if demand exceeds expectations.
Multiple Pricing Errors
When a product shows two different prices, customers are usually entitled to the lower price. Have a documented process for correcting shelf or online errors quickly, training staff on how to honour the lower price where required, and updating marketing materials promptly.
Unclear Delivery, Fees Or Surcharges
Surprises at checkout (unexpected insurance, mandatory “service fees” or inflated default shipping) are a common source of complaints. Keep optional fees optional, disclose compulsory fees upfront, and make it easy for customers to understand the true total before they commit.
How To Set Up Pricing Processes That Comply (Step-By-Step)
Good processes and clear documentation make compliance easier day to day. Here’s a practical setup you can follow.
1) Map Every Possible Cost In The Customer Journey
List all costs a typical customer may pay: product price, GST, delivery, handling, booking fees, gift wrap, payment surcharges, and so on. Decide which are mandatory (and should be in the single price) and which are truly optional.
2) Configure Your Website And POS To Display A Single Price
Set your product pages, catalogue templates and shelf labels to show a single price that includes GST and mandatory fees. For online stores, make sure the price the customer sees first is the price most customers will actually pay. Then present optional extras transparently with clear acceptance (not pre-ticked boxes).
3) Be Upfront About Delivery
If delivery varies, explain the variables early (e.g. location, weight, speed) and provide an easy way to estimate shipping before checkout. Don’t bury costly default options.
4) Build A Promotions Checklist
Before any promo goes live, run a quick checklist: Is the comparison price genuine? Are stock levels adequate? Are terms and exclusions clear and prominent? Are dates real and enforced? Does every touchpoint (ads, emails, website, shelf tickets) use the same compliant price and wording?
5) Train Your Team
Give your team short pricing guidelines: how to communicate fees, what to do if a ticket shows two prices, when to escalate a pricing error, and how to handle questions about discounts and RRPs.
6) Keep Consistent Legal Policies On Your Site
Your website should set clear rules and expectations for customers. Publishing well-drafted Website Terms & Conditions and appropriate returns and warranty information helps align your promises with the ACL and reduces disputes.
7) Honour Mistakes Quickly And Record Your Fix
Pricing errors happen. A simple policy - honour the lower price where required, communicate openly, and correct displays and listings fast - goes a long way. Keep a record of the error and fix so you can prevent a repeat.
8) Sense-Check Claims With A Consumer Lens
Ask: “Would a typical customer see this ad or product page and come away with the right understanding of total price and value?” If not, simplify the message or bring key conditions closer to the headline price.
What Legal Documents Will Help You Manage Pricing And Promotions?
Strong, clear documents support your pricing and reduce the risk of misunderstandings.
- Online Store Terms: If you sell online, tailored Online Store Terms set out ordering, pricing, delivery, cancellations and returns in plain English.
- Website Terms & Conditions: Your Website Terms & Conditions explain how customers can use your site, how product information and pricing is presented, and how errors are handled.
- Warranties Against Defects Policy: If you offer additional warranties, a compliant Warranties Against Defects Policy ensures the required ACL wording and details are provided to customers.
- Competition Terms & Conditions: For giveaways or discount competitions, clear Competition Terms & Conditions set entry rules, prize values, dates and disclaimers - which helps avoid misleading promos.
- Terms Of Trade (Wholesale): If you supply retailers, robust Terms of Trade set pricing, payment, rebates and promotional expectations across channels.
- Marketing & Promotions Guidelines (Internal): A short internal playbook for staff and agencies covering price display rules, discounting, use of RRPs, and approval steps before a campaign goes live.
Not every business needs all of these from day one, but most retailers benefit from having clear online terms and a consistent policy for warranties, returns and promotions. When your documents mirror your actual pricing practices, customers get a consistent experience and your team has fewer grey areas to navigate.
Pricing FAQs For Australian Retailers
Do I have to include GST in my advertised price?
Yes - if GST applies, your advertised price should generally be GST-inclusive. Separate GST-only price statements can confuse customers and risk breaching the single price rule.
Can I show a low price first and add mandatory fees later?
No - if a fee is unavoidable for most customers, it should be part of the headline price. Adding compulsory fees late in checkout is a classic example of “drip pricing”, which can mislead customers.
Is it okay to compare my price to an RRP?
Yes, provided the RRP is genuine and current for that product in your market. Avoid using inflated or outdated RRPs or implying savings that most customers can’t achieve.
What if I accidentally advertise the wrong price?
Act quickly. Correct the display or listing, honour the lower price where the ACL requires, communicate with affected customers clearly, and put in steps to prevent a repeat. Having consistent procedures and well-drafted online terms helps you respond confidently.
What else should I put on my website to reduce disputes?
Make sure your product pages, pricing, delivery information, and returns and warranty wording are consistent with the ACL. Publishing clear Website Terms & Conditions and honest warranty information supports a smooth customer experience.
Key Takeaways
- Australian Consumer Law requires that advertised prices are clear, honest and not misleading, with mandatory fees included in the single headline price.
- Watch for risk areas like “was/now” comparisons, RRPs, drip pricing, limited stock promos and multiple pricing - these are common sources of complaints.
- Build practical processes: map costs, configure your website and POS for single pricing, train your team, and use a promotions checklist before campaigns go live.
- For online stores, consistent Online Store Terms, Website Terms & Conditions and a compliant Warranties Against Defects Policy help align your promises with the ACL.
- If you use comparisons, ensure they’re genuine and current - misleading savings or inflated RRPs can breach Section 29.
- Getting tailored advice on your pricing practices and documents early can prevent costly mistakes later.
If you’d like a consultation on pricing compliance and advertising your goods correctly in Australia, you can reach us at 1800 730 617 or team@sprintlaw.com.au for a free, no-obligations chat.








