The Good Guys Ordered to Pay $13.5 Million for Misleading Store Credit Promotions

Australian retailers are again in the spotlight after the Federal Court ordered The Good Guys Discount Warehouses (Australia) Pty Ltd to pay $13.5 million in penalties for misleading conduct relating to store credit and “StoreCash” promotions.

The Good Guys fined $13.5m after misleading store credit promotions — highlighting ACCC enforcement and the importance of compliance in retail marketing.

This enforcement action, brought by the Australian Competition and Consumer Commission (ACCC), highlights the importance of transparency in promotional advertising and ensuring consumers receive what they are promised.

👉 Read the original ACCC media release here.

What Happened?

Between July 2019 and August 2023, The Good Guys ran 116 store credit promotions, offering customers between $10 and $1,000 in StoreCash when they met certain conditions — such as spending a minimum amount, buying specific products, or using a particular payment method.

The problem?

• The advertisements failed to properly disclose key conditions, such as expiry dates of just 7 to 10 days.

• In most cases, customers only received store credit if they remained subscribed to The Good Guys’ marketing emails.

• Around 21,500 consumers were not provided with store credits within the timeframes promised.

The Court found this conduct breached both the Australian Consumer Law and consumer protection provisions of the ASIC Act (since StoreCash is considered a financial service).

Why This Matters for Businesses

According to ACCC Chair Gina Cass-Gottlieb, these promotions likely influenced consumer behaviour:

“The chance to earn store credit may have encouraged some consumers to make a purchase at The Good Guys they otherwise may not have made, or to choose this retailer over others. We were concerned some of those consumers may not have done so had they been aware of all the conditions.”

The key lesson for businesses? Be upfront with consumers. Promotional offers must clearly set out expiry periods, conditions, and limitations. Failure to do so can result in:

• Court action

• Significant financial penalties

• Reputational damage

Outcome for Consumers

In addition to the $13.5 million penalty, The Good Guys must:

• Provide redress to eligible consumers who were impacted by undisclosed expiry periods, offering store credit with longer expiry terms.

• Contact affected customers directly.

• Continue remediation for the 21,500 customers who did not receive their credits within the promised timeframe.

The Good Guys has admitted liability, cooperated with the ACCC, and agreed to the Court’s orders.

Key Takeaways for Retailers

This case serves as a reminder for all businesses running marketing campaigns:

✔ Transparency is critical — always disclose key terms and conditions.✔ Deliver on promises — if you offer rebates, vouchers, or credits, ensure they are honoured within the stated timeframe.✔ Stay compliant — misleading promotions can attract the attention of regulators like the ACCC and ASIC.

Need Legal Guidance on Compliance?

At Bane Legal Services, we know how complex consumer law and compliance can be — especially when promotional campaigns are involved.

While we are not a law firm and do not provide legal advice, we draw on 30+ years of business experience to connect you with the right commercial lawyer for your situation.

If your business runs marketing promotions, loyalty programs, or customer incentives, having the right legal partner is essential to avoid costly missteps.

Contact Bane Legal Services today to be matched with a trusted lawyer who can protect your business and help you stay compliant.