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.
Running an online store means your refund and returns terms are doing real work every day. They need to answer customer questions clearly, but they also need to line up with the Australian Consumer Law.
It can be tempting to copy a refund policy template from somewhere online and publish it straight away. The problem is that a policy that sounds neat can still be risky if it says the wrong thing about faulty products, sale items, shipping costs or store credit.
The good news is that your policy doesn't have to be long or full of legal language. It just needs to be clear about what you offer voluntarily, while making sure you never take away rights customers already have under the law.
Do Australian Online Stores Need A Refund Policy?
No, the Australian Consumer Law doesn't force every online store to publish a separate refund policy. But in practice, you should have one because it sets expectations and helps your team handle returns consistently.
Your refund policy is different from the consumer guarantees and other rights customers already have under the Australian Consumer Law, often called the ACL. Those rights apply whether you write them down or not. Your returns and exchanges policy sits on top of those rights and explains how your store handles things like change of mind returns, return shipping, exchanges and timeframes.
A clear online store refund policy can help you:
- reduce customer service back and forth
- make your checkout experience feel more trustworthy
- give your team a clear process to follow
- avoid saying something that could mislead customers about their ACL rights
- protect your margins when you offer optional returns, like change of mind returns
If you're searching for a refund policy template for Australia, make sure you're looking for something built around Australian law. Overseas templates often refer to legal concepts that don't apply here, or miss key ACL rules about consumer guarantees and refund rights.
Templates can be a useful starting point, but they often still need a refund policy review to cover the details that matter for your store, such as whether you sell clothing, cosmetics, furniture, perishable goods, customised items or bundled products. A lawyer should tailor your policy before you use it.
What Does The Australian Consumer Law Require?
The ACL requires you to honour consumer guarantees, which means you can't refuse a remedy when a product doesn't meet the legal standard customers are entitled to expect.
The Australian Consumer Law is found in Schedule 2 to the Competition and Consumer Act 2010 (Cth). It's regulated nationally by the ACCC, as well as state and territory consumer regulators.
For goods sold online, the consumer guarantees generally include that products must:
- be of acceptable quality
- match the description, images or sample you provided
- be fit for any purpose the customer told you about, if they relied on your advice
- come with clear title and not have undisclosed security interests
- have spare parts and repair facilities available for a reasonable time, where relevant
Under the ACL, a customer can be a consumer even if they're another business, depending on the transaction. Since 1 July 2021, many purchases up to $100,000 are covered, and some goods are covered even above that threshold if they're ordinarily acquired for personal, domestic or household use.
If the problem is minor, your business can usually choose the remedy, such as a repair, replacement or refund. For example, if a product has a small defect that can be fixed quickly and without much inconvenience to the customer, you may be able to repair it first.
If there's a major failure, the customer can usually choose whether they want a refund, replacement or compensation for the drop in value. A major failure can include situations where the product is significantly different from the description or sample, unsafe, or substantially unfit for its normal or disclosed purpose and unable to be fixed easily within a reasonable time. It can also include goods that a reasonable consumer wouldn't have bought if they had fully known about the problem.
This is why your policy shouldn't say things like "no refunds under any circumstances" or "refunds are only available if we approve them". Those kinds of statements can mislead customers because they suggest your store has more control over ACL remedies than it actually does.
It's also worth separating consumer guarantees from any warranty against defects you offer. A warranty against defects is an extra promise, such as a 12 month warranty to repair or replace an item if a particular defect appears. It doesn't replace the ACL, and it isn't the same thing as a major failure.
What Can You Decide In Your Own Refund Policy?
Even though the ACL sets minimum rights, you still have room to decide how your store handles optional returns. This is where a refund policy template can be helpful, as long as it's tailored to your business.
For example, you can usually decide whether you offer change of mind returns. A customer doesn't automatically have a right to a refund just because they found the item cheaper elsewhere, chose the wrong size, changed their mind or no longer likes the colour, unless your own policy promises that option.
If you do offer change of mind returns, you can set reasonable conditions. These might include:
- the return must be requested within 14 or 30 days
- the item must be unused, unworn and in original packaging
- proof of purchase is required
- some items are excluded for hygiene, safety or customisation reasons
- the customer pays return shipping unless the item is faulty
You can also decide whether change of mind returns are refunded to the original payment method, exchanged, or provided as store credit. The key is to say this clearly before the customer buys.
Be careful not to use these conditions for faulty goods where the ACL gives the customer stronger rights. For example, if a product has a major failure, you generally can't insist on store credit instead of a refund just because that's what your change of mind policy says.
What Should A Refund Policy Template Include?
A good refund policy should be easy for customers to find, easy for your team to apply and specific enough to avoid confusion. It doesn't need to read like a long contract, but it should cover the common situations your store faces.
Most Australian online store refund policies should include:
- how customers can contact you to request a return
- what information they need to provide, such as order number, photos or proof of purchase
- your approach to faulty, damaged or incorrectly supplied items
- your approach to change of mind returns, including any time limits
- whether you offer refunds, exchanges or store credit for voluntary returns
- who pays return shipping in different situations
- how long refunds take to process once an item is received or approved
- any products that can't be returned for change of mind reasons
Your policy should also explain that it doesn't exclude or limit rights under the ACL. Many businesses include a short statement to this effect near the beginning or end of the policy. This helps make it clear that your store processes and voluntary returns are separate from the customer's statutory rights.
It's also a good idea to match your refund policy to the rest of your website terms. If your terms and conditions say one thing about returns and your refund policy says another, customers will understandably rely on the version that helps them most. Inconsistent documents can also make disputes harder to resolve.
Think about the customer journey as well. Your policy should be visible before checkout, not hidden in a place customers are unlikely to find. If you offer a generous returns window as a selling point, make sure the conditions are just as clear as the headline offer.
Common Refund Policy Mistakes To Avoid
One of the biggest mistakes online stores make is using absolute language. Phrases like "all sales are final", "no refunds on sale items" or "we don't accept returns after 7 days" can be risky if they aren't carefully qualified. You may be able to limit voluntary change of mind returns, but you can't remove ACL rights for faulty or misdescribed goods.
Sale items are a common trap. You can refuse change of mind returns on discounted products if your policy clearly says so. But if the sale item is faulty, not as described or otherwise fails a consumer guarantee, the customer may still be entitled to a remedy under the ACL.
Another mistake is forcing store credit in every situation. Store credit can be fine for voluntary returns if that's what your policy says. However, for a major failure, customers usually have the right to choose a refund rather than store credit.
Shipping costs also need careful wording. If the customer is returning an item because they changed their mind, it's common for them to pay return postage. If the item is faulty, damaged in transit before delivery, not as described or incorrectly supplied, your business may need to cover reasonable return shipping costs. If you want the item back before providing a remedy, make sure the process is practical and doesn't place an unfair burden on the customer.
Some stores also forget about digital products, subscriptions or pre orders. If you sell these, your refund policy should deal with them specifically. For example, you may need different wording for downloadable files, online courses, gift cards, deposits or made to order items.
How To Use A Refund Policy In Your Online Store
Once your policy is drafted, the next step is making sure it actually works in your business. A well written policy won't help much if your customer service team doesn't know where it is, or if your checkout promises something different.
Start by placing the policy somewhere customers can easily access. Common locations include your website footer, product pages, checkout page and order confirmation emails. If you're selling through a marketplace or social media shop, check whether that platform has its own returns rules as well.
Next, create a simple internal process. Decide who reviews return requests, what evidence you ask for and how quickly you respond. Customers are much less likely to become frustrated when they know what's happening and when they'll hear back.
It's also helpful to keep records of return requests, photos, correspondence and remedies provided. This can protect your business if there's a dispute, but it also gives you useful information about recurring product issues, sizing problems or supplier quality concerns.
Finally, revisit your refund policy whenever your business changes. If you add new product categories, start shipping internationally, sell bundles, launch subscriptions or change your delivery provider, your returns process may need an update too.
Key Takeaways
- You don't have to publish a refund policy under the ACL, but having one helps customers understand your process and helps your team stay consistent.
- Your policy can't take away consumer guarantees, including remedies for faulty, unsafe or misdescribed goods.
- You can set your own rules for change of mind returns, including timeframes, condition requirements and whether you offer refunds, exchanges or store credit.
- Avoid broad statements like "no refunds" or "all sales are final" unless they're clearly limited to voluntary returns and don't mislead customers about ACL rights.
- Your policy should clearly cover return steps, shipping costs, sale items, excluded products and refund timeframes.
- Templates are useful, but your refund policy should be tailored to your products, sales channels and customer experience.
If you'd like help with refund policy drafting, ACL compliance, returns terms and reviewing your online store policies, you can reach us at 1800 730 617 or team@sprintlaw.com.au for a free, no-obligations chat.







