Benchmarks · 8 reports · United Kingdom and Australia
208 customer flows, walked. Where each sector stands today.
One report per sector and market: what the rules name, counted across the sign-ups, checkouts and booking flows we walked. Anonymous by design. Each finding names the screen it sits on and the rule behind it.
Reports
Sector reports, by market.
United Kingdom
Consumer software and media
12 of 24 sign-up flows start with the annual or pricier plan already selected.
Australia
Online retail
9 of 21 checkouts advertise a delivery offer or discount and keep the conditions a click or scroll away.
United Kingdom
Online retail
11 of 21 checkouts advertise a discount or delivery offer whose conditions sit further down or in the terms.
United Kingdom
Subscription boxes
7 of 15 sign-up flows show a cheaper first box without saying what the boxes after it cost.
Australia
Travel and ticketing
6 of 32 booking flows add a fee that was not shown next to the first price.
United Kingdom
Travel and ticketing
5 of 28 booking flows only let you finish the booking once you sign in or create an account.
Australia
Subscription boxes
10 of 16 sign-up flows show the plan price without the delivery charge added to each order.
Australia
Telcos and ISPs
6 of 11 sign-up flows run online, but cancelling means a call, chat or email.
Your sector is not listed?
Tell us which one to walk next. Ten public flows, same method, no company named.
20-minute walkthrough
Your flow against the sector, in 20 minutes.
- 20 minutes
- Reviewed before the call
- No system access
- The two steps worth a look first, with the screen they sit on
- The rule each one touches, in the UK or Australia
- Where your flow sits against the sector benchmark, for you only
Across sectors
Seen in more than one sector.
Share of flows in each sector that show it on at least one screen. Only findings seen in two or more sectors; each links to its rule.
| What we saw | Consumer software and media30 sign-up flows walked | Online retail24 checkouts walked | Subscription boxes20 sign-up flows walked | Travel and ticketing36 booking flows walked | Sectors |
|---|---|---|---|---|---|
ASubscriptionsExpected January 2027 | |||||
| Term, renewal or exit not where the plan is chosenA · DMCC ss 256-257 A · DMCC ss 256-257Expected January 2027 Clear terms before sign-upPrice, renewal and how to end it, shown before the customer signs up. Read the rule, with examples → | 2 of 633% | not in scope | 2 of 633% | not in scope | 2 of 4 |
| Introductory price without the price that followsA · DMCC ss 256-257 A · DMCC ss 256-257Expected January 2027 Clear terms before sign-upPrice, renewal and how to end it, shown before the customer signs up. Read the rule, with examples → | 2 of 268% | not in scope | 7 of 1547% | not in scope | 2 of 4 |
| Exit harder than the sign-up, or not onlineA · DMCC s 260 A · DMCC s 260Expected January 2027 A straightforward exitEnding is straightforward, and online if the contract started online. Read the rule, with examples → | 2 of 2110% | not in scope | 2 of 1911% | not in scope | 2 of 4 |
BFees and total priceIn force since April 2025 | |||||
| Pre-selected add-on or defaultB · CCR reg 40 B · CCR reg 40In force since 2014 Paid extras need a clear yesNo paid extra without a deliberate yes; pre-ticked is not a yes. Read the rule, with examples → | 12 of 2450% | 6 of 2425% | 7 of 1547% | 4 of 3611% | 4 of 4 |
| Conditions one level deeper than the priceB · DMCC s 230 B · DMCC s 230In force since April 2025 Total price up frontThe price shown includes every charge the customer has to pay. Read the rule, with examples → | 4 of 2615% | 11 of 2152% | 4 of 2020% | – | 3 of 4 |
| Fee after the advertised priceB · DMCC s 230 B · DMCC s 230In force since April 2025 Total price up frontThe price shown includes every charge the customer has to pay. Read the rule, with examples → | – | 8 of 2236% | 4 of 1625% | 3 of 339% | 3 of 4 |
CBanned and unfair practicesIn force since April 2025 | |||||
| Account required before the checkoutC · DMCC ss 226-228 C · DMCC ss 226-228In force since April 2025 Misleading or pressuring, in contextPrices and key facts as clear as the decision needs, without undue pressure. Read the rule, with examples → | 4 of 3013% | – | 5 of 2025% | 5 of 2818% | 3 of 4 |
DConsentIn force | |||||
| Refusing cookies harder than accepting themD · PECR reg 6 D · PECR reg 6In force; amended February 2026 Cookies wait for a clear choiceNon-essential cookies need consent first; refusing is as easy as accepting. Read the rule, with examples → | 9 of 1947% | 10 of 2050% | 14 of 1782% | 23 of 3272% | 4 of 4 |
| Marketing consent ticked in advanceD · PECR reg 22 D · PECR reg 22In force since 2003 Marketing emails need a clear opt-inNo marketing emails or texts without consent; a pre-ticked box is not consent. Read the rule, with examples → | 3 of 1619% | 6 of 2326% | 10 of 1567% | 3 of 2811% | 4 of 4 |
Counts from one walk per flow, desktop, guest, 5 Oct 2026 to 7 Oct 2026. A flow counts once per finding. The pricing and unfair-practice rules have applied since April 2025; the subscription regime is expected January 2027. None of this is a verdict; it is what is worth a look.
| What we saw | Online retail24 checkouts walked | Travel and ticketing34 booking flows walked | Subscription boxes20 sign-up flows walked | Telcos and ISPs20 sign-up flows walked | Sectors |
|---|---|---|---|---|---|
BFees and total priceFrom 1 July 2027 | |||||
| Fee after the advertised priceB · s 48A B · s 48AFrom 1 July 2027 Fees beside the priceFees paid with the price are shown beside the base price. Read the rule, with examples → | 2 of 2010% | 6 of 3219% | 10 of 1663% | – | 3 of 4 |
CGeneral prohibitionFrom 1 July 2027 | |||||
| Conditions one level deeper than the priceC · s 28B C · s 28BFrom 1 July 2027 No manipulation, no undue pressureNo design that manipulates or unreasonably distorts the decision. Read the rule, with examples → | 9 of 2143% | 3 of 349% | 7 of 1937% | 2 of 2010% | 4 of 4 |
| Pre-selected add-on or defaultC · s 28B C · s 28BFrom 1 July 2027 No manipulation, no undue pressureNo design that manipulates or unreasonably distorts the decision. Read the rule, with examples → | 2 of 248% | 2 of 346% | 7 of 1937% | 6 of 2030% | 4 of 4 |
DConsentIn force | |||||
| Marketing consent ticked in advanceD · Spam Act s 16 D · Spam Act s 16In force since 2004 Marketing messages need consentCommercial emails and texts need consent; a pre-ticked box is not express consent. Read the rule, with examples → | 9 of 2143% | 2 of 248% | 9 of 1464% | 2 of 633% | 4 of 4 |
Counts from one walk per flow, desktop, guest, 5 Oct 2026 to 6 Oct 2026. A flow counts once per finding. Rules under the Act apply from 1 July 2027 and mark what will need a look. Consent rules (D) already apply.
Method
How the benchmark is made.
Public flows, walked as a guest
Each flow was walked in a desktop browser set to the market's language, time zone and storefront, from the entry page to the last screen before payment or personal data. Cookie banners were read before the first click and spot-checked from the market; banners shown only to visitors from other countries were left out. Nothing was bought, no account was created, no personal data was submitted.
One screenshot per observation
An observation counts only with a screenshot, the URL, the step number, the date and the exact wording on the screen. Uncertain observations are not counted.
Rule, not verdict
Each pattern is matched to the provision it touches. It marks a screen worth a look, not a legal finding: whether a rule applies depends on facts a public walk cannot see.
Anonymous by design
No company is named, quoted or identifiable. Examples are written as categories. The sample is drawn from the sector, not from clients, and no participant was told.
20-MINUTE WALKTHROUGH
Bring one flow.
We walk it before the call.
Choose one checkout, sign-up or cancellation flow. We review it before the call so we can focus on what matters.
- 20 minutes
- Reviewed before the call
- No system access
Founder of Flowlane