What happens when a client isn’t happy with a beauty treatment?

Does a salon have to give them a refund?

Can you have a “no refunds” policy?

What happens if the client simply doesn’t like the result?

And can a signed consent form protect the salon from having to provide a remedy?

These are some of the most misunderstood areas of running an Australian beauty business.

Beauty salons and beauty professionals providing services to consumers have obligations under the Australian Consumer Law (ACL).

These obligations can apply whether you operate:

• a large salon
• a skin clinic
• a nail salon
• a lash or brow business
• a home beauty salon
• a mobile beauty business
• another business supplying beauty services to consumers.

Understanding the difference between a client simply changing their mind and a service failing to meet a consumer guarantee is particularly important.

Important: This article provides general educational information for Australian beauty businesses. It does not constitute legal advice. Consumer-law outcomes depend on the individual circumstances of each situation.

What Is Australian Consumer Law?

Australian Consumer Law provides consumers with rights when purchasing goods and services.

For beauty businesses, this affects much more than product refunds.

It can apply to:

• beauty treatments
• packages
• salon products
• gift cards
• advertising
• promotions
• representations about results
• pricing
• sales practices.

Consumer rights provided by law cannot simply be removed by a salon’s own terms and conditions.

This means your salon policies need to work alongside Australian Consumer Law, rather than attempt to replace it.

Consumer Guarantees Apply to Beauty Services

When a consumer purchases a service, certain guarantees apply automatically under Australian Consumer Law.

For beauty businesses, three of the most important concern:

Due care and skill

Services must be provided with due care and skill.

In practical terms, this means the therapist should exercise an appropriate level of care and professional skill when performing the treatment.

Fitness for a particular purpose

In circumstances where a client makes their particular purpose or desired result known and relies on the business’s expertise, additional consumer guarantees concerning fitness for purpose or achieving a particular result may apply.

This is one reason beauty professionals should be careful about promising specific treatment outcomes.

Reasonable time

Where no time for supplying the service has been agreed, the service must generally be supplied within a reasonable time.

What is “reasonable” will depend on the circumstances.

A Client Being Unhappy Doesn’t Automatically Mean They Are Entitled to a Refund

This distinction is extremely important.

A client saying:

“I don’t like it.”

does not automatically establish that the salon has breached Australian Consumer Law.

The question is whether the service failed to meet an applicable consumer guarantee.

For example, consider a client who requests a particular brow shape.

The therapist performs the service competently and exactly as agreed, but the client later decides they preferred their previous shape.

That situation may be different from one where the therapist ignored the agreed shape or performed the service without appropriate care and skill.

Similarly, beauty treatments don’t always produce identical outcomes for every person.

A disappointing result does not automatically prove that the salon did something wrong.

The facts matter.

What If the Treatment Wasn’t Performed With Due Care and Skill?

If a beauty service fails to meet a consumer guarantee, the remedy depends partly on the seriousness and nature of the problem.

Australian Consumer Law distinguishes between problems that can be remedied and major failures.

This distinction affects who decides what happens next.

Problems That Can Be Fixed

Where a problem with a service is not a major failure and can be remedied, the business generally has an opportunity to fix the problem within a reasonable time.

In a beauty setting, whether something can appropriately be fixed will depend on the circumstances.

A suitable remedy might potentially involve:

• correcting part of a service
• repeating an appropriate service
• providing another reasonable solution.

However, beauty businesses should never attempt to “fix” a problem by performing another treatment when doing so would be unsafe or inappropriate.

Client safety comes first.

For example, repeatedly treating irritated or compromised skin simply to avoid discussing a refund would not be an appropriate response.

What Is a Major Failure With a Service?

A service can have a major problem in circumstances including where:

• a reasonable consumer would not have acquired the service had they known about the nature and extent of the problem
• the service is substantially unfit for its normal purpose and cannot easily be made fit within a reasonable time
• the consumer told the business about a particular purpose and the service is substantially unfit for that purpose and cannot easily be corrected
• the service creates an unsafe situation.

Whether a particular beauty-treatment complaint amounts to a major failure depends on the facts.

Businesses should therefore avoid making automatic decisions such as:

“We never refund treatments.”

What Happens When There Is a Major Problem?

Where a service has a major failure, Australian Consumer Law can give the consumer the right to cancel the service contract.

Depending on the circumstances, they may also be entitled to a refund for the unused portion or compensation reflecting the reduced value of the service.

The precise remedy depends on what happened and what services were actually supplied.

This is another reason salon owners should investigate complaints rather than applying the same response to every situation.

Can a Beauty Salon Have a “No Refunds” Policy?

A salon should not use a blanket policy stating:

NO REFUNDS

or:

NO REFUNDS UNDER ANY CIRCUMSTANCES

where that statement suggests consumers cannot exercise rights they have under Australian Consumer Law.

Your salon cannot contract out of applicable consumer guarantees simply by putting a statement on:

• the reception desk
• your website
• your booking system
• your consultation form
• a receipt
• your terms and conditions
• Instagram.

Your salon can establish policies for circumstances where the consumer doesn’t have a statutory right to a remedy.

The important distinction is that your policy cannot remove rights the law provides.

What About Change of Mind?

Australian Consumer Law does not generally require a business to provide a refund simply because a consumer changes their mind.

For example, a client purchasing an eligible retail product and then deciding they no longer want it is different from returning a product because it is faulty.

A salon may choose to have a more generous change-of-mind policy.

If you advertise such a policy, make sure the terms are clear and that your business follows what it promises.

“No Change-of-Mind Refunds” Is Different From “No Refunds”

This is a useful distinction when writing salon policies.

A statement explaining that the salon does not provide refunds simply for change of mind is very different from stating that the salon never provides refunds.

Your policies should preserve the client’s rights under Australian Consumer Law.

For example, a salon might explain that change-of-mind refunds are not normally offered while also making clear that nothing in the policy excludes rights available under Australian Consumer Law.

What If a Client Signed a Consent Form?

A signed consent form is important, but it isn’t a magic waiver.

A client signing a treatment consent form does not automatically remove the salon’s obligations under Australian Consumer Law.

Consent forms can provide valuable evidence that:

• the treatment was explained
• relevant risks were discussed
• contraindications were considered
• aftercare was provided
• the client agreed to proceed.

But a statement such as:

“I accept all risks and agree that the salon has no responsibility for anything that happens”

should not be assumed to remove statutory consumer rights.

Beauty businesses should view consent as part of a professional consultation and risk-management process—not as permission to provide services without due care and skill.

Expected Treatment Reactions Are Different From Negligent Treatment

Many legitimate beauty treatments can produce temporary effects.

Depending on the service, these may include:

• redness
• tenderness
• temporary swelling
• dryness
• mild sensitivity
• temporary changes in appearance.

Where appropriate, these possibilities should be discussed during consultation and aftercare.

However, describing something as an “expected reaction” does not automatically make every adverse outcome acceptable.

If a complaint arises, consider:

• what treatment was performed
• whether it was appropriate for the client
• whether contraindications were identified
• whether correct procedures were followed
• what the client was told beforehand
• what products or equipment were used
• whether the therapist acted with appropriate care and skill.

Good records become extremely important at this point.

What If the Client Didn’t Follow Aftercare?

Client behaviour after treatment can also be relevant.

Suppose a client was clearly instructed to avoid a particular activity after treatment but chose not to follow the advice.

That may be relevant when determining what caused the problem.

This is why aftercare should be:

• appropriate
• understandable
• provided consistently
• documented where appropriate.

Don’t rely entirely on:

“I definitely told her.”

Written aftercare instructions can provide a clearer record of the advice provided.

However, an aftercare sheet does not excuse problems caused by an improperly performed treatment.

What About Unrealistic Expectations?

Expectation management is an important part of consumer-law compliance.

Beauty therapists should be careful about promising outcomes they cannot guarantee.

Statements such as:

“This will completely remove your pigmentation.”

“Your teeth will definitely whiten by 12 shades.”

“This treatment permanently removes cellulite.”

“You will definitely get these exact results.”

can create problems if they are inaccurate or cannot be substantiated.

Instead, consultation should explain realistic expected outcomes and factors that may affect results.

Your advertising and consultation process should tell a consistent story.

Advertising Claims Matter

Australian Consumer Law prohibits misleading or deceptive conduct and false or misleading representations.

Beauty businesses should therefore consider the overall impression created by:

• websites
• social media
• treatment descriptions
• before-and-after photographs
• brochures
• advertisements
• staff explanations
• promotional offers.

A salon shouldn’t promise extraordinary results in its advertising and then rely on fine print in its consultation form when those results don’t occur.

Before-and-After Images

Before-and-after photographs can communicate claims just as words can.

Avoid using:

• filters
• beauty modes
• skin smoothing
• digital teeth whitening
• body reshaping
• substantially different lighting
• misleading camera angles
• different posture intended to exaggerate results.

The image should fairly represent the treatment outcome.

What About Deposits?

Deposits are commonly used by beauty salons to secure appointments.

Australian Consumer Law does not simply prohibit beauty businesses from taking booking deposits.

However, businesses should make the terms clear before the client books or pays.

This can include:

• the deposit amount
• whether it is applied to the treatment price
• cancellation requirements
• rescheduling conditions
• circumstances in which the deposit may be retained.

Cancellation charges and deposit-retention policies should also be reasonable and should not be designed merely to punish the consumer.

We will cover this subject separately in our guide to beauty salon deposits, cancellation fees and no-shows.

Packages and Prepaid Treatments

Beauty salons frequently sell packages such as:

6 treatments for the price of 5

or prepaid courses of treatments.

These arrangements should have clear terms.

Consider explaining:

• what is included
• treatment frequency
• expiry or validity conditions where lawful
• transferability
• cancellation conditions
• what happens if the client becomes unsuitable for treatment
• what happens if the business can no longer provide the service.

Australian Consumer Law continues to apply to services sold as part of a package.

A package agreement should not attempt to remove statutory consumer rights.

Gift Cards and Gift Vouchers

Beauty businesses selling gift cards should also understand the national gift-card rules.

In general, gift cards supplied on or after 1 November 2019 must have a minimum three-year expiry period.

The expiry date must generally be prominently displayed.

There are exceptions to the three-year requirement for certain types of cards and promotional vouchers.

Salon owners should therefore determine whether what they are selling is an ordinary gift card or falls within an exception.

Avoid simply copying an old salon gift-voucher template that says:

“Expires in six months.”

That may not comply with the current rules.

What If a Client Complains?

The way a salon handles a complaint can determine whether a small problem becomes a major dispute.

A useful process is:

1. Listen

Allow the client to explain what has happened.

Avoid immediately becoming defensive.

2. Document the Complaint

Record:

• the client’s concern
• date of treatment
• therapist
• products used
• equipment or settings where relevant
• photographs where appropriate and consented to
• symptoms or outcome reported
• communications with the client.

3. Review the Treatment Record

Check:

• consultation
• contraindications
• treatment notes
• consent
• products
• equipment settings
• aftercare.

4. Assess Client Safety

If there may be an injury, adverse reaction or medical issue, don’t focus solely on the refund dispute.

Appropriate client care comes first.

Beauty therapists should also avoid diagnosing medical conditions outside their professional scope.

5. Determine What Remedy May Be Appropriate

Consider whether:

• there has been a failure to meet a consumer guarantee
• the issue can safely and appropriately be remedied
• it may constitute a major failure
• a refund or other remedy may be required.

6. Communicate Clearly

Explain the proposed resolution calmly and in writing where appropriate.

7. Notify Your Insurer Where Necessary

If the complaint involves an injury, significant adverse event, formal demand or potential insurance claim, check your insurance notification requirements.

Do not inadvertently prejudice your insurance position by ignoring a reportable incident.

Don’t Automatically Admit Liability

There is a difference between treating a client professionally and immediately making a legal admission.

Statements such as:

“This is completely our fault.”

may be inappropriate before the circumstances have been investigated.

A better initial response can acknowledge the client’s concern, arrange an assessment and explain that the business will investigate what occurred.

Where a serious injury or legal claim is involved, contact your insurer and obtain appropriate professional advice.

Don’t Automatically Deny Responsibility Either

The opposite approach can be equally problematic.

Responding with:

“You signed the form, so it’s your problem.”

is unlikely to be an appropriate complaint-management strategy.

A signed consultation form doesn’t automatically eliminate Australian Consumer Law obligations.

Investigate first.

Keep Good Treatment Records

Good records protect clients and businesses.

Depending on the treatment, records may include:

• consultation information
• contraindications
• treatment performed
• products used
• batch numbers where appropriate
• device and settings
• treatment duration
• therapist
• consent
• before-and-after photographs where appropriate
• aftercare provided
• reactions or incidents.

Records can become particularly important when the salon and client remember events differently.

Train Staff on Refund Policies

Having a legally appropriate policy is not enough if staff don’t understand it.

Receptionists and therapists should know that they should not automatically tell a client:

“We don’t do refunds.”

Train staff to recognise the difference between:

• change of mind
• dissatisfaction
• a potentially defective service
• an adverse event
• a complaint involving possible consumer guarantees.

Where staff are unsure, the matter should be escalated to the appropriate manager.

Your Terms and Conditions Should Not Attempt to Override the Law

Review the wording used throughout your business.

Look at:

• booking terms
• website terms
• appointment confirmation emails
• consultation forms
• receipts
• signs
• package agreements
• gift cards.

Watch for statements such as:

NO REFUNDS

ALL SALES ARE FINAL

THE SALON ACCEPTS NO RESPONSIBILITY

BY SIGNING THIS FORM YOU WAIVE ALL RIGHTS

These statements can potentially create problems if they misrepresent rights consumers have under Australian law.

A Better Approach to Salon Refund Policies

A professional salon policy should distinguish between different situations.

Change of mind

Explain your business’s policy.

Appointment cancellation

Explain your booking and cancellation terms.

Problems with a service

Explain that concerns should be reported promptly so the business can assess them.

Consumer guarantees

Make clear that your policy does not exclude rights available under Australian Consumer Law.

This creates a much more professional policy than simply writing:

NO REFUNDS.

When Should You Seek Advice?

Consider obtaining professional advice where:

• a client alleges injury
• a significant financial claim is made
• legal correspondence is received
• the client threatens legal proceedings
• there is uncertainty about whether a major failure occurred
• multiple clients report similar problems
• a regulator contacts the business
• the matter may need to be reported to your insurer.

The ACCC provides information about Australian Consumer Law but generally does not resolve individual disputes between businesses and consumers.

State and territory consumer-protection agencies may also provide information and dispute-resolution options.

Beauty Salon Consumer Law Checklist

Review your business and ask:

• Do our services meet applicable consumer guarantees?
• Do staff understand the requirement to provide services with due care and skill?
• Have we removed blanket “no refunds” statements?
• Do our policies distinguish change of mind from statutory consumer rights?
• Are our booking terms clear before clients pay?
• Are deposit and cancellation conditions clearly explained?
• Are treatment packages accompanied by clear terms?
• Do our gift cards comply with current gift-card rules?
• Are advertising claims accurate and supportable?
• Do our before-and-after photographs fairly represent results?
• Do consultation forms avoid suggesting clients waive all legal rights?
• Do we provide appropriate written aftercare?
• Do we maintain adequate treatment records?
• Do staff know how to escalate complaints?
• Do we know when an incident should be reported to our insurer?
• Do we periodically review our policies against current Australian Consumer Law guidance?

Where to Check Current Information

Australian Competition and Consumer Commission — ACCC

The ACCC provides guidance about:

• Australian Consumer Law
• consumer guarantees
• refunds and remedies
• advertising
• misleading conduct
• gift cards
• consumer rights.

The ACCC has also published guidance specifically for businesses providing personal services, including beauty and hairdressing services.

Because legislation and regulatory guidance can change, businesses should always check current ACCC information rather than relying on old salon policy templates.

State and Territory Consumer Protection Agencies

Depending on where your business operates, your state or territory consumer-protection agency can also provide information about consumer rights and business obligations.

The Bottom Line

Australian Consumer Law doesn’t mean that a beauty salon must refund every client who is unhappy.

But it also means a salon cannot simply create a “no refunds” policy and assume that ends the matter.

The correct question is:

Why is the client requesting a remedy?

If they have simply changed their mind, the salon’s normal policy may apply.

If there is a problem with the service, consider whether an applicable consumer guarantee has been met.

If there has been a failure, the appropriate remedy will depend on the nature and seriousness of the problem.

The best protection for a beauty business is a combination of:

appropriate training

realistic advertising

professional consultation

informed consent

good treatment records

clear policies

and

a fair complaint-handling process.

Understand the difference between your salon’s policies and the rights provided by Australian Consumer Law.

Your policy can establish how your business operates.

It cannot take away rights provided by law.

This article provides general educational information for Australian beauty professionals and businesses. It does not constitute legal advice. Consumer rights and remedies depend on the individual circumstances of each transaction and may change. Businesses should consult current ACCC guidance and obtain professional advice where required.