Alex is Sprintlaw’s co-founder and principal lawyer. Alex previously worked at a top-tier firm as a lawyer specialising in technology and media contracts, and founded a digital agency which he sold in 2015.
A clear, fair and legally compliant refund policy does more than reduce disputes - it builds trust with customers and protects your business.
If you sell goods or services in Australia, a “no refunds” sign won’t cut it. The Australian Consumer Law (ACL) sets minimum consumer guarantees and remedies you can’t contract out of. So your refund policy template needs to match what the law actually requires, while still guiding your team on how to handle returns day-to-day.
In this guide, we’ll walk you through what a refund policy is, what to include in a practical refund policy template, how to tailor it for different business models (retail, online, services, digital products), and the common pitfalls to avoid so you stay on the right side of the ACL.
What Is A Refund Policy (And Why Does It Matter)?
Your refund policy explains how your business handles returns, exchanges, repairs, replacements and refunds. It’s the document you point customers to when something goes wrong - or when they simply change their mind - and it helps your team make consistent decisions.
Done right, it should do three things:
- Reflect the consumer guarantees under the Australian Consumer Law (ACL).
- Set clear, fair processes and timelines that your staff can follow.
- Reduce the risk of disputes by setting expectations upfront.
It’s also part of a bigger compliance picture alongside your online shop terms and conditions, Privacy Policy and any warranties against defects policy you offer. Keeping these documents aligned avoids mixed messages and legal risk.
Refund Policy Template: Core Sections To Include
You don’t need lots of legal jargon. You do need accuracy, clarity and structure. Use the following headings as a practical refund policy template you can tailor to your business.
1) Purpose And Scope
- Explain that your policy outlines customer rights and how you handle returns, repairs, replacements and refunds.
- State the types of products or services covered (e.g. physical goods, digital downloads, subscription services, made-to-order items).
2) Australian Consumer Law Statement
- Confirm that your business complies with the ACL and that customers are entitled to remedies for major and minor failures.
- Make it clear you don’t exclude or limit consumer guarantees. Avoid wording that could be seen as misleading under section 18 of the ACL.
3) Change Of Mind Returns
- Set your own policy for returns where there is no fault (e.g. return within 30 days in new, unused condition with tags/packaging).
- Note any categories excluded for hygiene or customisation reasons (e.g. pierced jewellery, personalised items, perishable goods), if applicable.
- Be upfront about proof of purchase requirements.
4) Faulty Products Or Services
- Explain how you handle minor failures (usually repair or replacement) and major failures (refund or replacement at the customer’s choice).
- Set out the process to report an issue and the information you need (photos, order number, description of the problem).
5) Timeframes And Process
- Give practical timeframes for lodging a request, assessment, and issuing a remedy.
- Outline shipping or return logistics (who pays return postage when there’s a fault vs change of mind).
- Tell customers how you process refunds (original payment method, estimated processing times).
6) Exclusions And Fair Use
- List reasonable exclusions (e.g. damage from misuse, unauthorised repairs, normal wear and tear).
- Avoid exclusions that attempt to remove consumer guarantees - those won’t be enforceable.
7) Sale Items, Bundles And Gift Cards
- Confirm that faulty sale items still receive ACL remedies.
- Explain how you handle partial returns on bundles.
- Set rules for gift cards and store credit (expiry dates must comply with Australian gift card requirements).
8) Services, Bookings And Cancellations
- For services, outline what happens when you or the customer cancels or reschedules.
- Only charge reasonable fees and ensure any cancellation fees aren’t unfair or misleading.
9) How To Contact Us
- Provide a contact email, phone number and business address.
- If you have different channels (in-store vs online), tell customers which to use.
10) Updates To This Policy
- Reserve the right to update the policy and note the effective date so customers know the current version.
Sample Refund Policy Template (Copy And Tailor)
Use this as a starting point and tailor it to your operations. Make sure your final policy is consistent with the ACL and your other website documents.
Refunds, Returns & Repairs Policy Purpose This policy explains how handles returns, repairs, replacements and refunds. Our policy applies to purchases made for . Your Rights Under Australian Consumer Law Our goods and services come with guarantees that cannot be excluded under the Australian Consumer Law. You are entitled to a replacement or refund for a major failure and compensation for any other reasonably foreseeable loss or damage. If the failure is not major, you are entitled to have the goods repaired or replaced within a reasonable time. Change Of Mind If you change your mind, we may offer an exchange or store credit when goods are returned within days, unused and in original packaging with proof of purchase. The following items are not eligible for change of mind returns: . Faulty Or Not As Described If an item is faulty, unsafe, or not as described, please contact us within a reasonable time with your order number, description of the issue and photos (if applicable). For major failures, you can choose a refund or replacement. For minor failures, we will repair or replace within a reasonable time. Return Shipping For faulty items or our error, we cover return shipping or provide a prepaid label. For change of mind returns, you are responsible for return shipping. Services, Bookings And Cancellations If you need to cancel or reschedule a booking, please notify us in advance. A reasonable cancellation fee may apply for late cancellations or no-shows, where permitted by law. Sale Items, Bundles And Gifts You are entitled to ACL remedies for faulty sale items. For bundle purchases, partial returns will be valued proportionately. Gift cards and store credit are valid until . Proof Of Purchase We accept as proof of purchase. Contact Us Email: Phone: Address: Last updated:
Important: Don’t include statements like “no refunds for sale items” or “no refunds under any circumstances”. These can be misleading or unlawful if they imply customers have fewer rights than the ACL provides.
How To Tailor Your Refund Policy For Different Models
Not every business handles returns the same way. Here’s how to tailor your template based on what you sell and how you sell it.
Online Stores
- Include returns logistics, prepaid labels and whether you refund original shipping on change of mind returns.
- Keep your refund terms consistent with your online shop terms and conditions and your checkout disclosures.
- If you accept orders for pre-sale or backorder, explain expected timeframes and options if delays occur.
Brick-And-Mortar Retail
- Use clear in-store signage and ensure staff know when repairs, replacements or refunds apply.
- Avoid blanket “no refunds” signage - it can breach the ACL.
Services And Bookings
- Define what counts as a major vs minor problem with the service and how you’ll remedy it (e.g. re-perform the service or provide a refund for a major failure).
- Set reasonable notice periods and fees for cancellations or no-shows. Make sure your approach to cancellation fees is fair and transparent.
Digital Products And Subscriptions
- Clarify access issues, defects and compatibility. Explain when you will repair, replace or refund for a major failure of a digital product.
- Be clear about renewal dates, free trials and pro‑rata refunds where legally required.
Made-To-Order Or Custom Products
- Explain that change of mind returns may not be possible once production starts, but ACL remedies still apply for faulty or not-as-described items.
Common Mistakes To Avoid (ACL Pitfalls)
Here are frequent issues we see with DIY refund policies - and simple ways to avoid them.
- “No refunds” statements: Avoid absolute wording that removes ACL rights. Instead, clarify when change of mind returns are offered and confirm ACL guarantees still apply.
- Hidden or vague fees: Be upfront about restocking and shipping fees for change of mind returns. Fees must be reasonable and clearly disclosed.
- Misleading guarantees: If you offer your own warranty, align it with a compliant warranties against defects policy and avoid suggesting it replaces ACL rights.
- Inconsistent web copy: Ensure your refund policy matches your product pages and promotional claims to avoid issues with misleading or deceptive conduct.
- Pricing discrepancies: If there’s an error in the advertised price, handle it carefully and consistently with your policy and advertised price laws.
- Collecting personal data without transparency: If you gather customer details during returns, make sure your Privacy Policy covers what you collect and why.
Where To Display Your Refund Policy (And How To Roll It Out)
Even the best policy won’t help if customers can’t find it or your team doesn’t follow it. Make it visible and train staff on the process.
- Website placement: Link your refund policy in the footer and at checkout. Keep wording consistent with your online shop terms.
- In‑store signage: Keep signs simple and compliant (e.g. “We comply with Australian Consumer Law. Ask us about your rights.”). Avoid absolute statements.
- Order confirmations: Include a link to the policy in invoices and order emails.
- Staff training: Provide a short script and escalation pathway for tricky cases.
- Record‑keeping: Keep a log of returns, reasons and outcomes. This helps spot patterns and defend decisions if a complaint escalates.
How Your Refund Policy Fits With Your Other Legal Documents
Think of your refund policy as one piece of your legal “stack”. For consistency and compliance, align these documents and processes:
- Customer-facing terms: Make sure refund terms match your Online Shop Terms & Conditions or website terms of use.
- Warranties: If you offer a commercial warranty, ensure the wording is compliant and sits alongside your warranties against defects policy.
- Privacy: Returns often involve collecting names, emails and bank details. Your Privacy Policy should cover returns processing and how you handle that personal information.
- Marketing claims: Keep product descriptions, promotions and fine print consistent to avoid issues with false or misleading representations under the ACL and section 18. If you reference specific features or benefits, ensure they’re accurate and not overstated.
Step-By-Step: Draft And Launch Your Refund Policy
Step 1: Map Your Scenarios
List your most common return situations: change of mind, wrong size, faulty on arrival, fails after use, service cancellations, digital access issues. Your policy should give a clear pathway for each.
Step 2: Decide Your Operational Settings
Set practical rules your team can deliver consistently (return windows, proof of purchase, restocking fees, return shipping, repair partners and turnaround times).
Step 3: Embed ACL-Compliant Wording
Include an ACL statement, avoid absolute exclusions, and get the “major vs minor failure” remedies right. If in doubt, speak with a consumer law lawyer to sanity-check your draft.
Step 4: Align With Your Website And Sales Flow
Update your product pages, cart and checkout to reflect how returns work. Keep messaging consistent across your policy, promotional offers and any “limited time” claims to avoid misleading conduct.
Step 5: Train Your Team And Publish
Publish the policy on your website, add it to order confirmations, update in-store signage, and provide a simple internal guide so staff know when to repair, replace or refund.
Step 6: Review After 60-90 Days
Check return volumes, reasons and customer feedback. Tweak your processes, stock checks and product descriptions to reduce preventable returns.
FAQs: Quick Answers To Common Questions
Can I Refuse Change Of Mind Returns?
Yes - change of mind returns are a business choice, not a legal requirement. If you offer them, set clear conditions (time limits, condition of goods, proof of purchase). ACL remedies still apply for faulty items.
Can I Charge A Restocking Fee?
Only for change of mind returns, and the fee must be reasonable and clearly disclosed. Don’t apply fees to ACL remedies for faulty or not‑as‑described products.
Do I Have To Refund Original Shipping?
For change of mind, many businesses don’t refund original shipping (if clearly stated). For faulty goods, you generally cover return costs and refund the original shipping if the item was not as described or has a major failure.
What If I Priced An Item Incorrectly?
Handle price errors consistently with your policy and be mindful of advertised price laws. If a price was obviously incorrect, you may not need to honour it - but take care with how you communicate and remedy the situation.
Key Takeaways
- Your refund policy must reflect the Australian Consumer Law - you can’t exclude consumer guarantees or use “no refunds” wording that misleads customers.
- Start with a clear template: purpose and scope, ACL statement, change of mind rules, faulty item remedies, timeframes, exclusions, bookings/cancellations, and contact details.
- Tailor the policy to your model (online, in‑store, services, digital products, custom orders) and keep it consistent with your Online Shop Terms & Conditions and Privacy Policy.
- Avoid common pitfalls like hidden fees, inconsistent web copy, and non‑compliant warranty statements - keep wording accurate and transparent.
- Make the policy easy to find, train your team to follow it, and review it regularly based on return data and customer feedback.
- If you’re unsure about the legal wording or edge cases, getting quick advice from a consumer law lawyer can save time and prevent disputes.
If you’d like a consultation on drafting or reviewing your refund policy for your Australian business, you can reach us at 1800 730 617 or team@sprintlaw.com.au for a free, no‑obligations chat.


