Who can produce the price history behind a struck-through number? Most retail teams cannot answer that on the spot, and as of November 10, 2026 the question has become operational: the ACCC has opened its third sweep of promotional claims, and for the first time it is reading websites, emails and social media together. The list of what it is checking is short: sitewide claims where large numbers of products are excluded, countdown timers that outlive their stated end date, scarcity messaging that invents low stock, and sale prices compared against reference prices the product was never or not recently sold at. The file a retailer can produce is now the difference between a defence and a finding.
Four claims, one file
Read as an industry trend, this is a shift in what discounting has to prove. For a decade the constraint was margin: how deep can we go. The constraint now is evidence: can we show the number was real. Promotional depth has not disappeared, it has become documented, and the documentation sits with whoever owns the price file.
The shopper side has moved too. When 58 per cent name low prices as their reason to participate, a claim that cannot be substantiated is not a marketing risk, it is a demand risk: the shopper who arrives expecting the reference price and finds a different one leaves, and writes about it.
The reference price is the only number that needs proof
Every promotional claim reduces to two numbers: what you charge now, and what you say it used to be. The first is operational. The second is a representation about the past, which is why regulators ask for it and why teams struggle to produce it after a replatform or a price file migration.
| Claim type | What must exist | Typical failure |
|---|---|---|
| Was / now | Dated price history | History lost in migration |
| Percentage off | Base price and period | Base lifted before the sale |
| Sitewide | Exclusion list | Exclusions in fine print only |
| Countdown | Stated end time | Timer resets after expiry |
A seven-day audit
Days one and two: rebuild the history
Export the last ninety days of prices for every SKU in the promotion, including the days it was not on sale. Without that baseline, no percentage can be defended, and the exercise stops being a compliance task and becomes a guess.
Days three to five: match claims to numbers
Take each live claim on the page, in the email and in the social post and match it to the baseline. Where a claim covers a range rather than a product, list the exclusions explicitly and check that the excluded share is small enough for the headline to stay honest.
Days six and seven: fix the edges
The edges are where findings come from: timers that continue past the end date, scarcity messages driven by a stale feed, and sitewide banners left running after the eligible range shrinks. Each is a small engineering fix and each is exactly what the sweep is designed to catch.
Where teams get caught
The most common exposure is not a fabricated price, it is an inherited one. A reference price set by a previous team, carried into a new template, and never re-checked against the history is still a representation, and it is still the retailer's to defend. The second is the channel gap: a page corrected while the email and the social post are not.
The third is the timer. Countdown mechanics convert well, which is why they survive redesigns, and they are also the easiest claim to disprove: a shopper who screenshots an expired timer has the whole case. Setting the timer to the promotion record rather than to the page removes the risk entirely.
FAQ
Does the sweep apply to emails and social posts?
Yes. This is the first year the ACCC has said it will read websites, emails and social media together, which means a correction in one channel is not enough.
How far back does price history need to go?
Ninety days covers most reference-price questions and survives a template change. Anything shorter risks a gap exactly where the claim sits.
Are sitewide claims ever acceptable?
Yes, if the excluded share is disclosed and small. The problem is a headline that implies everything is included when a large number of products are not.
What is the cheapest control to add?
Tie timers and banners to the promotion record rather than to the page, so they stop when the promotion stops without anyone remembering to switch them off.
