The Australian Competition and Consumer Commission (ACCC) has released its 2026-27 Compliance and Enforcement Priorities, framing its agenda around ongoing cost of living pressures, protecting vulnerable consumers and the dynamics of fast moving digital markets. The ACCC has also indicated it will continue seeking higher penalties for deliberate misconduct and improving where it considers compliance culture to be deficient.

This year’s priorities closely track broader consumer and market concerns and follow the same structural approach the ACCC has taken in previous years.

1. Emerging concerns

The ACCC has identified concerns around:

1. rising costs and limited competition in key markets;
2. manipulative and false practices in digital markets (including subscription traps / dark patterns; and
3. restrictions on small or large businesses imposed by other parties, which the ACCC believes may inhibit ​​​
   effective competition.

2. Ongoing priorities

The ACCC continues to treat the following areas as long‑term priorities because it believes they pose serious risks to competition and consumer welfare:

1. cartel conduct;
2. anti‑competitive agreements and exclusionary behaviour;
3. product safety issues with potential for serious harm;
4. impacts on vulnerable consumers and First Nations consumers;
5. protections for small business, including agriculture; and
6. scam detection and disruption.

3. The ACCC’s 2026-27 annual priorities

Supermarkets and retail

The ACCC states it will prioritise supermarket and retail markets, focusing on firms with market power and practices that it believes may harm small businesses or mislead consumers, including pricing and discount representations.

Essential services: telecommunications, electricity and gas

The ACCC has identified competition and consumer issues in essential services, including misleading pricing and claims in energy and telecommunications, where it believes complexity and lack of transparency can lead to consumers and small businesses not being able to make effective choices.

Aviation

The ACCC will continue to prioritise aviation, citing concerns about pricing transparency and the availability of remedies when services are not delivered as promised.

Digital markets

The ACCC remains focused on digital markets, including:

1. manipulative online design practices (for example, dark patterns such as subscription traps)¹,
2. unsafe consumer goods sold online; and
3. promoting competition where the ACCC believes platform power may distort market conditions.

Environmental and sustainability claims (greenwashing)

Greenwashing remains a major priority. The ACCC has signalled a focus on environmental and sustainability claims where it believes such claims may be misleading or cannot be substantiated. This continues a multi‑year focus on ESG representations.

See here for previous articles we have written on this issue: Article-1, Article-2, Article-3, Article-4.

Unfair contract terms

The ACCC reports it will prioritise enforcement around contract terms it believes may disadvantage consumers or small businesses, such as automatic renewals, cancellation barriers and early termination fees.

See here for our article series on the unfair contract terms reforms.

Consumer guarantees (motor vehicles)

The ACCC has indicated that it will increase its compliance focus on consumer guarantees, particularly in the automotive space, where the ACCC believes that failure to provide timely repair, refund or replacement options remains prevalent. It will be interesting to see whether this increased focus is confined to customer complaints, or whether the ACCC also intends to scrutinise the extent of automotive manufacturers’ liability to indemnify dealers. More broadly, the landscape around consumer guarantees continues to evolve. Since 2021², the Australian Government, working alongside State and Territory Consumer Affairs Ministers and industry stakeholders, has been developing potential civil prohibitions and penalty regimes for breaches of the consumer guarantees and the supplier indemnification provisions in the Australian Consumer Law. Although the reform program is still underway, it is gaining momentum, and further concrete proposals are expected in the near term as the Government advances its consumer protection agenda.³

Product safety for young children

The ACCC will continue targeting compliance with mandatory standards for button batteries, infant sleep, and toppling furniture where it believes gaps may lead to significant injury risk. See here for previous articles Article-1 and Article-2 written on button batteries safety standards.

4. Penalties, accountability and compliance expectations

The ACCC indicates it will pursue higher penalties for deliberate misconduct and increase its focus on senior executive accountability, particularly where it believes poor compliance culture is contributing to risk.

How we can help you

In light of where the ACCC believes key risks lie, businesses should expect greater scrutiny in 2026-27, particularly in digital environments, pricing practices, environmental claims and high‑risk sectors such as energy, telecommunications, supermarkets and motor vehicles.

We have a dedicated consumer law team that can help you review your contracts and business practices to ensure compliance with the ACL, and to strengthen your overall compliance framework in light of the areas the ACCC believes warrant closer scrutiny. If you would like more information about the services we provide, please contact us.

This article was written by Teresa Torcasio, Partner and Caitlyn White, Special Counsel.

¹ See: www.accc.gov.au/media-release/accc-warns-consumers-to-beware-of-subscription-traps

² Decision Regulation Impact Statement Improving consumer guarantees and supplier indemnification provisions under the Australian Consumer Law December 2025.

³ Ministers Treasury Portfolio: Stopping unfair trading: subscription traps and hidden fees targeted 23 November 2025.