Refund Policy Wording: What to Say (and What You Can’t) for Australian Online Businesses

Last updated: 24 March 2026

Getting your refund policy wording right is not optional – it is a legal requirement and a customer trust signal rolled into one. Write it too broadly, and you expose yourself to disputes. Write it too restrictively, and you may be breaching the Australian Consumer Law (ACL).

Drawing on 17 years of working with more than 10,200 Australian online businesses, Legal123 has seen the same refund policy mistakes made repeatedly across every business type – and the legal and commercial consequences that follow.

This guide covers what every Australian refund policy must include, the phrases you are legally prohibited from using, and twelve ready-to-adapt examples across the most common online business types.

What Australian law requires your refund policy to cover

Australian law requires your refund policy to acknowledge consumer guarantee rights under the ACL and explain your process for handling refund requests – it cannot deny or override those rights.

Under the Australian Consumer Law, consumers have automatic rights when a product or service fails to meet consumer guarantees. Your policy cannot take those rights away. What it can do is clarify your process, set reasonable timeframes, and communicate what you offer beyond the legal minimum.

Every compliant Australian refund policy should address:

• When a refund will be provided (including where ACL consumer guarantees apply)
• When a refund will not be provided (change of mind, used or opened items, digital products after download, etc.)
• How a customer requests a refund and what evidence they need to provide
• How long does refund processing take
• The method of refund (original payment method, store credit, etc.)
• Any time limits on making a claim

Phrases you legally cannot use in Australia

Several common refund policy phrases are illegal under the ACL in Australia, or are likely to be found misleading, because they suggest consumers have no rights at all.

In our experience reviewing thousands of Australian business websites, these are the phrases we see most often – and the ones most likely to attract ACCC scrutiny. Do not use them in any form:

• “No refunds under any circumstances”
• “No refunds or exchanges”
• “We do not offer refunds”
• “All sales are final”
• “Refunds are not available for change of mind or any other reason”
• “By purchasing, you waive all rights to a refund”

Why these are illegal: They imply consumers have no refund rights whatsoever. The ACCC can issue infringement notices, and courts can award significant penalties. Even if your restriction applies only to change-of-mind purchases, blanket statements like these are still unlawful because they imply that no rights exist under any circumstances.

Instead, these phrases are legally sound and commercially realistic:

• “We do not offer refunds for change of mind”
• “Refunds for change of mind are at our discretion”
• “We comply with the Australian Consumer Law and provide refunds where required”
• “Digital products cannot be refunded once downloaded, except where required by law”
• “Cancellations made within [X] hours of booking are non-refundable”

Refund policy wording for online stores (ecommerce)

For ecommerce businesses selling physical products, the key rule is this: you must provide a remedy for faulty, damaged, or misdescribed goods under the ACL, but you are not legally required to accept change-of-mind returns.

Physical product businesses face the most consumer guarantee exposure – faulty goods, goods not matching their description, and goods not fit for purpose all trigger mandatory refund rights. Change-of-mind returns are entirely at your discretion.

General ecommerce store

Change of mind: We do not offer refunds or exchanges for change-of-mind purchases. Please choose carefully before completing your order.

Faulty or incorrect items: If your item arrives faulty, damaged, or materially different from its description, you are entitled to a remedy under the Australian Consumer Law. Please contact us at [email] within 30 days of delivery with your order number and photos of the issue. Depending on the nature of the fault, we will offer a refund, replacement, or repair.

How to request a refund: Email [email] with your order number, a description of the problem, and supporting photos where relevant. We process approved refunds to your original payment method within 5-7 business days.

Return shipping: For faulty items, we cover return shipping costs. For discretionary returns, shipping costs are the customer’s responsibility.

Nothing in this policy limits your rights under the Australian Consumer Law.

Shopify store

If you run a Shopify store, do not use Shopify’s default refund policy – it is written for the US market and is not ACL-compliant. Replace it entirely with the following wording.

Returns window: We accept returns within 14 days of delivery for faulty or misdescribed items. We do not accept returns for a change of mind.

To start a return: Email [email] with your order number and the reason for your return. Do not return items without contacting us first – unauthorised returns cannot be processed.

Condition of returned items: Items must be unused, in original packaging, and accompanied by proof of purchase.

Refunds: Once we receive and inspect your return, we will notify you of the outcome within 3 business days. Approved refunds are issued to your original payment method within 5 business days.

Your consumer rights under the Australian Consumer Law apply regardless of this policy.

Dropshipping store

For dropshipping businesses, your refund policy must be honest about extended timelines – your supplier’s returns process governs what you can actually deliver, and overpromising creates disputes you cannot fulfil.

Faulty or damaged items: If your order arrives faulty, damaged in transit, or does not match the product description, contact us at [email] within 14 days of delivery. We will arrange a replacement or refund at no cost to you. Please include your order number and clear photos of the issue.

Change of mind: We do not offer refunds or exchanges for change-of-mind purchases. Due to the nature of our fulfilment process, we cannot always accept returned items. Please review product descriptions and sizing guides carefully before ordering.

Processing time: Due to international supplier logistics, replacement processing may take 10-20 business days. We will keep you updated throughout.

This policy does not limit your rights under the Australian Consumer Law.

Etsy seller

For Etsy sellers, your refund policy must comply with both ACL requirements and Etsy’s own seller policies – the key distinction is between personalised items (generally non-returnable) and standard stock items.

Returns: I accept returns on non-personalised items within 14 days of delivery, provided items are in original, unused condition. Buyers are responsible for return postage costs.

Personalised and custom orders: Personalised items cannot be returned unless they arrive faulty or materially different from what was agreed. Please review all spelling, dates, and details carefully before submitting your order.

Faulty items: If your item arrives damaged or incorrect, contact me within 7 days with photos, and I will arrange a replacement or full refund, including any shipping costs you incurred.

Your Australian Consumer Law rights apply to all purchases.

Refund policy wording for digital products

For digital products, you can legally restrict change-of-mind refunds once a file has been downloaded or accessed – but consumer guarantees still apply if the product is faulty or does not work as described.

Digital products – ebooks, templates, software files, audio, and similar downloads – have no physical return mechanism. Under the ACL, consumer guarantees still apply, but you can reasonably limit change-of-mind refunds once the file has been accessed.

Downloadable products (ebooks, templates, graphics)

No change-of-mind refunds: Due to the digital nature of our products, we do not offer refunds for change of mind once a file has been downloaded or accessed.

Technical issues: If you are unable to download your file, or if the file is corrupt or does not function as described, contact us at [email] within 14 days of purchase. We will either resolve the issue or provide a full refund.

Product descriptions: Please read product descriptions, file specifications, and compatibility requirements carefully before purchasing. We are happy to answer questions before you buy.

Nothing in this policy removes your rights under the Australian Consumer Law, including your right to a refund where a product fails to meet consumer guarantees.

Software and SaaS (subscription or one-time licence)

For software and SaaS businesses, the main refund question is around subscription cancellations and pro-rata billing – the standard position is no pro-rata refund for unused time, with a short cooling-off window for annual plans.

Subscriptions: You may cancel your subscription at any time. Cancellations take effect at the end of your current billing period. We do not provide pro-rata refunds for unused time within a billing cycle.

Annual plans: Annual subscriptions are non-refundable after 14 days of purchase, except where required by the Australian Consumer Law.

Technical faults: If our software fails to function as described and we are unable to resolve the issue within a reasonable time, you are entitled to a refund for the affected billing period.

Cancellation process: Cancel via your account settings or by emailing [email]. We do not accept verbal cancellations.

This policy operates alongside your rights under the Australian Consumer Law.

Refund policy wording for online courses

For online courses, the key is to specify a clear refund window tied to content access – most providers use a 7-to-14-day window with a completion percentage cap to prevent abuse.

Online courses require careful policy design because once the course content is accessed, the product is effectively consumed. Be specific about what triggers a refund and what does not.

Self-paced online course

7-day satisfaction guarantee: We want you to feel confident in your purchase. If you are not satisfied with the course content, request a refund within 7 days of purchase, and we will issue a full refund – no questions asked – provided you have completed no more than 20% of the course material.

After 7 days: We do not offer refunds after 7 days of purchase or once more than 20% of course modules have been accessed, except where required by the Australian Consumer Law.

Technical access issues: If you experience a genuine technical barrier that prevents access to the course and we cannot resolve it within 5 business days, you are entitled to a full refund.

To request a refund: Email [email] with your name, purchase date, and reason for the request within the eligible period.

Live or cohort-based course

For live and cohort-based courses, a tiered cancellation policy based on notice period is standard – this reflects the real cost of holding a place and the difficulty of filling last-minute vacancies.

Cancellation by you: Full refund if cancelled more than 14 days before the course start date. 50% refund if cancelled 7-14 days before the start date. No refund for cancellations within 7 days of the start date or for non-attendance.

Transferring your place: You may transfer your enrolment to a future cohort once, at no charge, provided you request this at least 7 days before the start date.

Cancellation by us: If we cancel or postpone a course, you will receive a full refund or the option to transfer to an alternative date.

Your rights under the Australian Consumer Law apply regardless of the above.

Refund policy wording for coaching and consulting services

For coaching businesses and consulting businesses, the core principle is that completed work and delivered sessions are non-refundable, but unused packages and undelivered work should be refundable on a pro rata basis.

Service-based businesses have more flexibility than product sellers, but still need clear cancellation windows, forfeiture rules for late cancellations, and provisions for what happens when the provider cannot deliver.

Coaching sessions (hourly or package)

Session packages: Unused sessions in a package may be refunded on a pro-rata basis at any time, less a 10% administration fee. Sessions are forfeited if not used within [X months] of purchase.

Cancellation and rescheduling: We require 24 hours’ notice to reschedule or cancel a session. Sessions cancelled with less than 24 hours’ notice will be forfeited.

Refund of completed sessions: We do not offer refunds for coaching sessions that have already been delivered.

Where a session cannot be delivered: If we are unable to deliver a session due to unforeseen circumstances on our end, we will reschedule at your convenience or refund the session in full.

This policy does not affect your rights under the Australian Consumer Law.

Consulting and professional services (project or retainer)

Project-based work: All deposits are non-refundable once work has commenced. If a project is cancelled by the client after commencement, payment is due for all work completed to the cancellation date, plus any expenses incurred.

Retainer agreements: Monthly retainer fees are non-refundable once the month has commenced. Retainers may be cancelled with 30 days’ written notice.

Unused retainer credits: Where an agreed scope of work is not delivered in a given month due to circumstances on our part, unused credits will be carried over to the following month.

Disputes: If you believe a deliverable does not meet the agreed specification, please contact us in writing within 7 days of delivery, and we will work to resolve the issue in good faith.

Nothing in this policy limits your rights under the Australian Consumer Law where applicable to services.

Refund policy wording for events and workshops

For events and workshops, a tiered refund policy based on the notice period is the standard approach – a full refund for early cancellations, a partial or no refund close to the event date, and a full refund if the event is cancelled by the organiser.

Tickets purchased by you: Full refund if cancelled more than 21 days before the event. 50% refund if cancelled 8–21 days before the event. No refund within 7 days of the event date. Ticket transfers to another person are permitted at no charge with at least 48 hours’ notice.

Event cancelled or postponed by us: If we cancel, you will receive a full refund of your ticket price within 10 business days. If we postpone, you may transfer your ticket to the new date or receive a full refund.

Force majeure: In circumstances beyond our reasonable control (natural disaster, government direction, public health emergency), we will offer credit toward a future event, but cannot guarantee cash refunds.

Your statutory rights under the Australian Consumer Law are not affected by this policy.

Refund policy wording for memberships and subscriptions

For membership and subscription businesses, the standard position is no pro-rata refunds for partial billing periods, with a short cooling-off window for annual plans before content is accessed.

Cancellation: You may cancel your membership at any time via your account settings or by emailing [email]. Your membership will remain active until the end of the current billing period.

Monthly memberships: We do not offer pro-rata refunds for partial months. No refunds are issued for the current billing period after payment has been processed.

Annual memberships: Annual memberships are refundable within 14 days of initial purchase if you have not accessed member content. After 14 days, annual memberships are non-refundable, except where required by the Australian Consumer Law.

Free trials: Cancellation before the end of a free trial period incurs no charge. If you do not cancel before the trial ends, your subscription converts to a paid plan, and standard cancellation terms apply.

This policy does not remove your rights under the Australian Consumer Law.

Refund policy wording for custom-made products and bespoke services

For custom-made products, refunds for change of mind are generally not required under the ACL – but you must still remedy items that are faulty or do not match the agreed specification.

Because custom work is created specifically for one customer, businesses have strong grounds to limit returns – provided the customer was given a clear opportunity to approve the specification before production began.

Custom and personalised orders: Because custom-made products are created specifically for you, we do not offer refunds or exchanges for change of mind, incorrect sizing provided by the customer, or design choices made by the customer after approval.

Approval process: Before production commences, we will provide a proof or design confirmation for your approval. Once you approve, we proceed with production, and the order is final.

Faulty or incorrect items: If your custom item arrives with a manufacturing defect or does not meet the approved specification, we will remake or refund the item at our expense. Contact us at [email] within 7 days of delivery with photos.

Nothing in this policy limits your rights under the Australian Consumer Law where the product fails to meet consumer guarantees.

Refund policy wording for food businesses (online)

For online food businesses, refunds are generally not required for a change of mind on perishable goods, but you must provide a remedy if the food arrives damaged, spoiled, or materially different from what was ordered.

Perishable items: Due to the perishable nature of our products, we do not offer refunds or exchanges for change of mind, ordering errors, or failure to be present for delivery.

Damaged or incorrect orders: If your order arrives damaged, spoiled, or materially different from what you ordered, contact us at [email] within 24 hours of delivery with photos. We will offer a replacement, credit, or refund at our discretion.

Allergies and dietary requirements: Customers are responsible for checking all product ingredients and allergen information before ordering. We cannot accept returns or issue refunds for failure to check allergen information, unless the product was mislabelled.

Your rights under the Australian Consumer Law apply where a product fails to meet consumer guarantees.

Refund policy wording for health and fitness services

For health and fitness businesses, the key considerations are cancellation notice requirements, what happens to unused sessions in a pack, and how to handle genuine medical circumstances.

Personal training

Session packs: Sessions in a purchased pack may be refunded on a pro-rata basis for any unused sessions within 30 days of purchase. After 30 days, unused sessions are non-refundable but may be gifted to another person with written notice.

Cancellation notice: We require 24 hours’ notice to cancel or reschedule a session. Sessions cancelled with less than 24 hours’ notice are non-refundable.

Injury or medical condition: If you are unable to continue training due to a medical condition verified by a GP or specialist, we will credit your remaining sessions for use when you are cleared to return.

This policy is in addition to your rights under the Australian Consumer Law.

Allied health and massage

Appointment cancellations: We require 24 hours’ notice to cancel or reschedule an appointment. Cancellations with less than 24 hours’ notice, or non-attendance, will be charged at [50%/100%] of the appointment fee.

Prepaid packages: Prepaid treatment packages are non-refundable but are transferable to another person. Packages expire 12 months from the date of purchase.

Dissatisfaction with treatment: If you were dissatisfied with your treatment, please contact us within 48 hours, and we will do our best to address your concern, which may include a complimentary follow-up appointment.

Nothing in this policy affects your rights under the Australian Consumer Law.

Where to display your refund policy

Your refund policy must be easy to find – displaying it in at least four places on your website is best practice under the ACL, and helps protect you in any dispute.

An ACL-compliant policy that no one can locate gives you limited legal protection. Make sure your policy appears in:

• Website footer – linked on every page, always accessible
• Checkout page – ideally with a checkbox or visible summary near the buy button
• Order confirmation email – include a link or summary in every post-purchase email
• Terms and Conditions – your refund policy should be incorporated by reference or reproduced in your T&Cs
• Product pages – for high-value items, a brief refund summary on the product page reduces disputes

Frequently asked questions

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About the Author: Vanessa Emilio

Vanessa Emilio (BA Hons, LLB, ACIS, AGIA) is the Founder and CEO of Legal123.com.au and Practice Director of Legal123 Pty Ltd. Vanessa is a qualified Australian lawyer with 20+ years experience in corporate, banking and trust law. Click for full bio of Vanessa Emilio or follow on LinkedIn.

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