1. Start with what was observed
In our illustrative subscription example, the sign-up page shows an A$19 first-month offer. A separate terms page says the membership continues at A$49 per month. Those are the source facts. The numbered markers are Flowlane annotations, not text published by the example business.
The interpretation is that the recurring commitment is hard to find at agreement. Test that relationship against the actual source states. If another prominent disclosure exists beside sign-up, or the evidence misses a relevant state, the assessment may need to change.
2. Read the legal link and the outcome together
The report links ACL s 48D for subscription offer information, with the detailed subparagraphs available alongside the assumptions. The Act supplies the legal rule. The Explanatory Memorandum explains its intended operation; it is not a separate statutory obligation. The subscription example draws on EM paragraphs 1.116 and 1.120-1.122 for payment liabilities and disclosure near agreement.
‘Likely gap’ is an interpretation for the 2027 requirements on the stated assumptions. ‘No issue identified’ is limited to the inspected question and scope. ‘Needs evidence’ means a material question is unresolved. These outcomes are different answers; they are not three levels of whole-site compliance.
3. Check the scope before acting
The illustrated offer covers two desktop source states. It does not establish the mobile view, account process, delivery of notices or every subscription obligation. Read the scope and assumptions before assigning a task or using the finding in a wider assessment.
A useful next step is to show the ongoing price beside the sign-up information, then inspect the changed state. That is a proposal until the responsible team implements it. Fresh evidence is needed for a follow-up assessment. Keep the earlier finding and the new observation distinguishable so a reviewer can understand what was actually changed.
Sources and scope
Page updated: 7 October 2026. Applicability, exclusions and transitional arrangements need assessment by your advisers. Review the flow after every release.