The ACCC's gift card regime is a short list of obligations that catches a surprising number of small Australian businesses every year. The rules themselves aren't complicated. The trouble is that they apply more broadly than people think, and the consequences of getting them wrong are real - even when the breach is unintentional.
Here is the regime in plain English: what it covers, where small businesses most often slip up, and a practical checklist you can run through against your own voucher program in about five minutes.
This is general information, not legal advice. If your voucher model is unusual - promotional vouchers, charity fundraising, employee rewards, loyalty rewards, re-loadable cards, or time-limited event tickets - get advice before assuming the three-year rule applies in the usual way.
Most gift cards and vouchers purchased on or after 1 November 2019 must be redeemable for at least three years after they were supplied or purchased. The expiry date must be prominently displayed, or the voucher must clearly say that there is no expiry date. The terms cannot include post-supply fees that reduce the customer's redeemable balance, such as activation, account-keeping, balance inquiry, or inactivity fees. The ACCC lists exceptions, including certain re-loadable cards, promotional vouchers, loyalty programs, employee reward schemes, second-hand cards, genuine-discount cards, and some charity or government-supplied cards.
The three-year minimum expiry
Since 1 November 2019, most gift cards sold to consumers in Australia must have an expiry period of at least three years from the date they were supplied or purchased.
That is the floor, not the target. You can choose a longer expiry. You can choose no expiry. But if the three-year rule applies to your voucher, you should not be issuing it with twelve months, eighteen months, or two years.
This applies nationally. It is not a Victorian rule, a NSW rule, or a "big retailer" rule. It applies across Australia, and the ACCC can investigate and take compliance or enforcement action if a business breaks the rules.
Before the 2019 change, it was common for spas, restaurants, salons, clinics, and other service businesses to issue vouchers with six- or twelve-month expiries. Some businesses still do it because the old template never changed.
That is a risk. The non-compliant voucher usually does not look dramatic. It looks like last year's gift voucher, copied again.
For the deeper economic argument on why three years is actually good for your margins, see The ACCC three-year expiry rule, and why it's good for your margins.
What counts as a "gift card"?
The definition is broad. The ACCC describes a gift card as something usually loaded with an amount of money that can be exchanged for goods or services. It can be physical or electronic, including a card, voucher, or code sent electronically.
In practical terms, that can include plastic gift cards, digital vouchers delivered by email, mobile-ready digital vouchers, downloadable voucher views, QR codes or barcodes or other stored-value tokens, and store credit or return credit that functions like redeemable stored value.
Do not rely on the label.
Calling it a "voucher," "credit," "certificate," "experience card," or "store credit" does not automatically take it outside the rules. The safer question is:
Has the customer received something they can redeem later for goods or services?
If yes, treat it carefully.
The narrow exceptions
There are exceptions, and they matter.
The ACCC says the three-year rule does not apply to some categories, including cards that can be reloaded or topped up, cards donated for promotional purposes, cards available only for a specified period, cards supplied at a genuine discount, employee reward scheme cards, loyalty program cards, second-hand gift cards, some temporary marketing promotions, and cards supplied to certain charities or government agencies.
That does not mean every "special offer" avoids the rule.
It means you should know which category your voucher is in before setting an expiry shorter than three years.
For a normal paid gift voucher sold to a customer, start with the assumption that the three-year minimum applies unless you have a clear reason it does not.
The expiry date must be visible
A compliant expiry period is not enough. The customer also needs to be able to see it.
The ACCC says the expiry date must be prominently displayed. If the expiry is shown as a period of time, the issue date also needs to be displayed so the customer can work out the actual expiry date. If there is no expiry date, that also needs to be stated.
For digital vouchers, that means the expiry should be visible where the customer actually sees the voucher: the email, the voucher page, the digital voucher itself, and any customer-facing voucher view.
Hiding the expiry date in terms and conditions is not a good system. The expiry date exists somewhere in the terms and conditions, but it is not on the voucher itself. The customer does not see it until there is a dispute - and by then the record has already failed.
VoucherGrid makes the expiry date part of the voucher record and displays it on the digital voucher, the delivery email, and the online voucher page. If the voucher has no expiry, the voucher can say that clearly instead.
No fees that reduce the balance
The ACCC rules also prohibit post-supply fees.
That means a business cannot include terms that let it charge fees after the gift card has been purchased if those fees reduce the customer's redeemable value. The ACCC gives examples including activation fees, account-keeping fees, balance inquiry fees, and inactivity fees.
There are exclusions. For example, the ACCC says post-supply fees do not include certain booking fees, currency exchange fees, fees related to reissuing lost, stolen, or damaged cards, or payment surcharges.
For small businesses, the practical rule is simple: do not chip away at the voucher balance.
This catches more businesses than you'd expect. If you're charging an "admin fee" when someone redeems a voucher, or deducting a processing fee from the voucher balance, you are likely in breach.
VoucherGrid does not deduct admin, dormancy, account-keeping, or balance-check fees from voucher balances. Online payment processing is handled by Stripe through your connected Stripe account at the point of purchase - it never reduces the voucher's redeemable value.
Balance enquiries and old records
Customers should be able to find out the balance on a voucher without paying for the privilege. Balance inquiry fees are prohibited, and businesses should be able to answer balance questions for their customers.
If your voucher records are scattered across a spreadsheet you archived two years ago and a stack of carbon-copy books in a drawer, that's an operational problem before it's a compliance problem. The customer who asks "what's left on this?" deserves an answer in seconds, not a search through old folders.
VoucherGrid keeps voucher status and balance information available through the dashboard, so staff do not need to reconstruct the history manually. Additionally, we provide a dedicated balance-check page that voucher holders can check any time.
If an account is cancelled, personal information and retained records are handled according to VoucherGrid's Privacy Policy and data retention settings.
Where small businesses most often get it wrong
Most mistakes are not deliberate. They are inherited from an old template, an old booking system, or the way the business has "always done it."
| Mistake | What it looks like | Risk |
|---|---|---|
| Legacy expiry periods | Vouchers still going out with 6- or 12-month expiries | High |
| Unclear expiry display | Expiry hidden in terms, not visible on the voucher | High |
| Balance-reducing fees | Admin, inactivity, or balance-check fees deducted from value | High |
| Weak recordkeeping | Business cannot quickly answer "what was left?" | Operational / dispute risk |
| Assuming store credit is different | Return credit or goodwill credit treated as outside the rules without checking | Review needed |
| Old templates | Voucher wording has not been reviewed since 2019 | Review needed |
The last one is sneaky.
Store credit, return credit, goodwill credit, and promotional vouchers may not all be treated the same way. Some may fall into exceptions. Some may not. The danger is assuming the label decides the treatment. Review them properly.
A practical compliance checklist
If you sell gift vouchers in Australia, run through this list against your current voucher template and checkout flow.
01 · Does the voucher have at least three years validity? Use at least three years where the rule applies. Do not copy old twelve-month templates forward.
02 · Is the expiry date visible? The expiry date should be clear on the digital voucher, email, voucher page, and any customer-facing voucher view. If there is no expiry, say that clearly.
03 · Are there any post-supply fees? Check for account-keeping, inactivity, activation, balance inquiry, admin, or redemption fees that reduce the customer's redeemable balance.
04 · Can the customer check the balance without paying? Balance inquiry fees are not allowed. Your system should let you answer balance questions without charging the customer.
05 · Can you reconstruct the voucher history? For disputes, refunds, accounting, and customer service, you need issue date, expiry date, original value, redemptions, remaining balance, and status history.
06 · Have you reviewed store credit and promotional vouchers separately? Do not assume every credit note, goodwill credit, promotional voucher, or discount voucher is covered in the same way. Check the category and terms.
07 · Has the template been reviewed since November 2019? If nobody can remember, the answer is probably no.
How VoucherGrid handles this
VoucherGrid is built around these rules, but it should not be described as a legal guarantee. It gives the business a workflow that reduces the common failure points.
Expiry checks. VoucherGrid can help prevent expiry dates shorter than the required minimum where the three-year rule applies.
Clear expiry display. Every voucher carries its expiry information on the digital voucher, delivery email, and online voucher page.
No balance-reducing VoucherGrid fees. VoucherGrid does not deduct admin, dormancy, account-keeping, or balance-check fees from voucher balances.
Balance lookup. VoucherGrid keeps voucher status and balance available through the dashboard and balance-check flow, so staff do not need to reconstruct history manually.
Audit history. Every issue, redemption, refund, void, expiry, and adjustment is recorded against the voucher record.
Accountant-ready records. When vouchers expire with remaining balances, VoucherGrid surfaces the remaining value in reports your accountant can review for breakage and income recognition.
For the accounting side, see AASB 15 breakage, in four journal entries.
The one thing to action
Pull up the last voucher your business issued. Check four things:
- Is the expiry at least three years where the rule applies?
- Is the expiry date clearly visible?
- Are there any fees that reduce the balance after purchase?
- Can you answer "what is left?" without searching a drawer or charging the customer?
If any answer is not a clean yes, fix the template before the next voucher goes out.
Compliance is not a one-off project. It is a property of the system you use.