Black Friday Marketing for Small Business: ACCC-Safe Plan

Australians were forecast to spend a record $6.8 billion over the 2025 Black Friday to Cyber Monday weekend, according to an Australian Retailers Association media release dated 7 November 2025. Last week, on 29 September 2026, the ACCC announced that two retailers had paid penalties over sale claims from that same season. Both facts should shape how you approach Black Friday marketing for small business this year.

The ARA forecast put spending 4% above the previous year, with about 6 million Australians expected to take part and average planned spending of $804 per person. Shoppers will compare your deal with everyone else's. Black Friday falls on Friday 27 November and Cyber Monday on 30 November, so you have roughly seven weeks. That's enough time to do this in the right order: offer first, then email, ads, Google Business Profile and the landing page.

What has the ACCC penalised in Black Friday marketing?

Mostly fake deadlines and savings that don't hold up. James Lane and Vuly paid penalties after the ACCC issued infringement notices over sale end dates that weren't genuine. Its earlier sweep also flagged "sitewide" claims with exclusions, restrictive fine print, inflated was/now prices, shaky RRP comparisons and "up to X% off" headlines.

The details are worth reading closely. According to the ACCC's 29 September announcement, James Lane paid $19,800 after one infringement notice. It ran "Sale ends today!" messaging for a sale ending 3 December 2025, having already decided to keep the discount going, and then kept it for another week. Vuly paid $39,600 across two notices because its Click Frenzy and Black Friday countdown timers reset to new end dates after the sales had supposedly ended. Deputy Chair Catriona Lowe said businesses must make sure end dates, countdown timers and limited-time claims are genuine. Misleading pricing remains an ACCC enforcement priority.

The regulator's December 2024 Black Friday sweep covered the rest. Its 17 December 2024 release raised concerns about storewide or sitewide claims that carried exclusions, fine print that walked back the headline, was/now prices where the "was" figure may have been lifted before the sale, savings measured against an RRP the product hadn't recently sold at, and "up to" discounts where those two words were tiny or very few products got the top rate.

Step 1: Choose a Black Friday offer you can prove (this week)

Start with the numbers, not the creative. Pull the prices you actually charged for each product or service over recent months. If a "was" price only existed for a fortnight in October, it isn't a was price, and you should drop it in favour of a plain dollar or percentage discount off what customers normally pay.

Next, pick your dates and commit to them. If there's any chance you'll extend, don't write "ends Sunday". Announce the window you're sure of. Service businesses have it easier here: a gift voucher bonus or a booking offer for January appointments is simple to explain and hard to get wrong.

Step 2: Warm up your email list (weeks 1 to 4)

Your list will do more for you than any ad, provided people still recognise your name. Send two or three useful emails before you announce anything. Remove addresses that have bounced. Segment past buyers from browsers.

Then offer subscribers early access a day or two before the public sale. It rewards the people who signed up and gives you an early read on which products are moving. Before you send, check your list against the Australian consent rules, because a promotional blast to people who never opted in creates a different compliance problem.

Step 3: How much should you spend on Black Friday ads?

Spend what your margin can carry at the discounted price, not what feels competitive. Work out what one sale is worth after the discount, decide what you'll pay to win it, then set daily budgets from that figure. Competition for clicks usually rises in late November, so expect fewer per dollar than in September.

If you haven't run the maths before, our guide to setting a budget walks through it for Google Ads, and the same logic holds on Meta. Split spend into a smaller pre-sale phase to build audiences and a heavier push across the weekend itself.

Ad copy carries the same legal weight as your website. A headline saying "up to 60% off" needs the "up to" as visible as the number, and enough products at that discount to make it honest. A flat "20% off all furniture" is easier to defend, and easier for a shopper to understand at a glance.

Step 4: Update your Google Business Profile (week 6)

Local shoppers often find you through Maps before they reach your site. Add an offer post with the real start and end dates, a clear photo and a link to the landing page. Set special hours for the weekend so nobody turns up to a locked door, and answer any new reviews promptly while traffic is high.

Step 5: Build a landing page that matches the ads (weeks 5 to 7)

Keep it to one page that says exactly what's on sale. If some ranges are excluded, say so near the headline in normal-sized text, and don't call the sale sitewide. Show each discount next to the price it's taken from.

Countdown timers are fine when they count down to a real deadline. When the clock hits zero, the timer should show the sale has ended and the discount should come off. A timer that resets is exactly what the ACCC described in the Vuly case. At Searchline we build these pages for Australian small businesses, and the biggest fix is usually the same: make the page agree with the ad and the email word for word. Test it on your phone before anything goes live.

Common questions

Can I extend my Black Friday sale if it's going well?

You can run a new offer, but be careful about how you got there. James Lane's problem was telling customers the sale ended that day when it had already planned to continue. If you extend, announce it honestly as an extension and don't backdate your urgency.

Do these rules apply to service businesses?

Yes. A physio clinic advertising "up to 50% off" packages or a salon claiming a was/now saving faces the same expectations as an online retailer. Gift vouchers and booking incentives tend to be simpler offers to describe accurately.

Is October too late to start?

No. Seven weeks gives you time to check pricing history, warm up your list and get ads approved without rushing. The businesses that struggle tend to be the ones writing copy on the Thursday before.

Pick your offer this week and test it against the five practices the ACCC flagged in 2024. If you can defend every claim to a sceptical customer, you're ready to spend on getting it in front of them. Which part of your current plan would fail that test?