Key takeaways
- 9 of 21 checkouts: delivery offer or discount shown, conditions a click or scroll away. A free-delivery or discount claim should carry its conditions, such as excluded items, areas or members only, where the claim is shown.
- 2 of 20 checkouts: delivery charge missing next to the first price. A fee charged on every order or booking is shown beside the advertised price, not at the end of the flow.
- No new screen needed: each of the 4 findings is a label, a line or the order of a step.
What we saw across 24 checkouts walked
Each finding with the screen it sits on, the rule it touches and how big a change usually is (S label or text, M layout or order, L new screen or route). Walked against the full Flowlane checklist for Australia (16 checks); shown here: every finding that came up in more than one flow. Each number counts only the flows in which that step could be checked.
Every rule chip opens its card on the rules page.
| What we saw | Flows | Rule (market rules) | Change |
|---|---|---|---|
| Delivery offer or discount shown, conditions a click or scroll awayWhere it sits: Header banner, product page, delivery page | C · 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 →A free-delivery or discount claim should carry its conditions, such as excluded items, areas or members only, where the claim is shown. | MMedium | |
| Email or SMS marketing box already ticked when the checkout opensWhere it sits: Checkout contact step | D · 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 →Express consent to marketing messages needs an active choice; a pre-ticked box is not one. | SSmall | |
| Also seen in two or three flows | |||
| Delivery charge missing next to the first priceWhere it sits: Product list, checkout | B · 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 →A fee charged on every order or booking is shown beside the advertised price, not at the end of the flow. | SSmall | |
| Extra products ticked in advance in add-on pop-ups and bundlesWhere it sits: Pop-up after add to cart, product page | C · 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 →A paid extra the customer did not choose can steer the decision; add-on and bundle offers can start unticked. | SSmall | |
Three examples
Written as categories, no company identifiable.
Conditions
In one checkout, the header promised free delivery above a threshold with only an exclusions-apply note; the delivery page added that some remote postcodes are left out.
Fees
In one checkout, a toy of about $80 showed only a free-delivery threshold; the about $10 delivery charge came at checkout, and free pickup was offered only in another city.
Add-ons
In one checkout, a pop-up after the add-to-cart click showed four accessories, all ticked in advance and worth about $74 together, above a single add-all button.
What the rules ask
The Act received Royal Assent on 6 July 2026 and its rules apply from 1 July 2027; until then these are patterns that will need a look. The Spam Act rules on marketing consent already apply. Shown here: the rules this report touches.
Fees and total price
A fee that applies to every transaction is shown beside the base price, at the same time, as prominently. Where the amount is not yet known, how it is calculated.
General prohibition
No practice that manipulates or unreasonably distorts a decision: pressure that is not real, defaults that steer, obstacles to a choice the customer is entitled to make.
Consent
Commercial emails and texts need consent; a pre-ticked box is not express consent.
Check your own flow in ten minutes
One question per finding. A "no" is worth a look; it is not a verdict.
Not observed in this benchmark
What a public walk cannot show. Not part of the benchmark; included in a Flowlane review of your own flow.
Payment surcharges by card type
They show only after card details are entered, which a public guest walk-through does not do.
Included in a Flowlane review
We check each payment method with test cards.
Delivery cost behind the email step
In several checkouts the delivery price and options appeared only after an email address was entered.
Included in a Flowlane review
We walk it with a test identity you approve.
Returns and refund screens
They sit behind the order history of a customer account.
Included in a Flowlane review
We walk it with a test account you provide.
Method and anonymity
Same walk, same checklist, same rule mapping for every sector.
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
Your own flow against 24 walked flows, 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, under the Australian rules
- Where your flow sits against the sector benchmark, for you only