Inside Australia’s loyalty industry: what the ACCC report revealed

1 Junio 2026
Kate Pay

Loyalty programs have always reflected what brands think their customers value. For decades, that meant discounts, free products, and status perks. But something has shifted. Sustainability is now a mainstream loyalty driver, not a niche consideration for a minority of environmentally conscious shoppers. According to Comarch’s Global Customer Loyalty Predictions report, 64% of international shoppers consider sustainability an important factor in their purchasing decisions. A further 31% actively want sustainability-focused rewards in the loyalty programs they belong to.

And brands that are perceived as genuinely sustainable and socially responsible have seen a measurable 20% increase in customer loyalty as a result.

The logical conclusion: loyalty programs that reward sustainable behaviour aren’t just good for the planet. They’re good for business. But the execution is more complex than they might appear.

Why Sustainability Has Become a Loyalty Priority

The shift has been building for years, but several forces have accelerated it significantly heading into 2026.

Consumer values have evolved. Environmentally conscious consumers no longer consider just quality and price, they factor in the ethical and environmental impact of the brands they choose to engage with. For a growing segment of customers, particularly younger demographics, a loyalty program that ignores sustainability feels misaligned with their identity.

The business case has hardened. Brands that are perceived as sustainable command premium pricing, consumers are willing to pay, on average, a 35% premium for products from brands they view as environmentally responsible. Loyalty programs that connect rewards to sustainable behaviour reinforce that perception, and the commercial relationship it supports.

Regulatory pressure is also playing a role. Companies are under increasing scrutiny over their environmental commitments, not just from consumers, but from regulators. Loyalty programs that actively demonstrate sustainable outcomes provide measurable evidence of environmental impact, which increasingly feeds into ESG reporting and investor confidence

What Sustainability-Linked Loyalty Actually Looks Like

Sustainability-linked loyalty can come in a few different forms.

1. Rewarding Eco-Friendly Behaviours

The simplest and most direct approach: give members points, “beans,” badges, or tier progression for taking specific sustainable actions, not just purchasing.

Costa Coffee does this well. Members of the Costa Club earn additional “beans” (its points currency) when they bring a reusable cup to store. The mechanic is simple, verifiable, and directly tied to a tangible waste-reduction action. It also drives store visits, creating a commercial incentive that runs alongside the environmental one.

Etihad Airways has taken the aviation industry’s sustainability challenge head-on with its Conscious Choices program. Members can earn unique badges for eco-friendly behaviours, including flying with reduced baggage, which directly lowers fuel consumption and therefore emissions. Members can also contribute their Etihad Guest Miles to environmental causes, effectively redirecting the value of their loyalty currency toward environmental offsetting. For an industry almost synonymous with high carbon footprints, this represents a meaningful attempt to embed sustainability into the loyalty relationship.

2. Trade-In, Repair, and Circular Economy Models

Some of the most compelling sustainability-linked loyalty programs don’t reward purchasing at all, they reward not replacing.

Patagonia’s Worn Wear program is the most-cited example of circular loyalty in the industry, and for good reason. The program enables customers to trade in used Patagonia garments at any store location or by post. Items that can be resold are listed on the Worn Wear platform, and the original owner receives store credit of up to 50% of the item’s resale value. Items that can’t be resold are repaired, repurposed through the ReCrafted project — where multiple worn garments are combined to create new pieces, or recycled responsibly to avoid landfill.

The program works because it’s built on a genuine circular logic, not a marketing claim. Each repaired garment extends the product’s life, reducing the demand for new materials. Each trade-in generates a new customer interaction, and store credit that keeps the original customer in the ecosystem. Patagonia reported a 30% increase in sales following the program’s permanent launch, demonstrating that a model built around consuming less doesn’t necessarily mean earning less.

Madewell runs a similar mechanic for denim: loyalty members receive a discount when they return old jeans, which are then recycled and used to create home insulation. The environmental outcome, diverting denim from landfill, is directly tied to a reward, and the reward is only accessible to loyalty members, strengthening the program’s value proposition.

3. Charity and Tree-Planting Redemptions

An increasingly popular option: allowing members to redeem points for environmental causes rather than personal rewards. This works particularly well for members who are already highly engaged with a brand and for whom another free product or discount offers diminishing marginal value.

Yves Rocher has made environmental giving a core part of its loyalty identity. The brand rewards customers who choose eco-friendly products and allows members to direct engagement toward tree-planting initiatives. Since 2007, Yves Rocher has planted over 100 million trees through its foundation, a figure that loyalty engagement has contributed to meaningfully.

IKEA rewards loyalty members with special discounts when they purchase from its sustainable product lines, spanning furniture, textiles, and dining, and offers additional tips on sustainable living through the program. This approach connects purchasing incentives to sustainability education, reinforcing the brand’s stated commitment to becoming climate positive by 2030.

TripAdvisor’s eco-rewards campaigns have planted 150,000 trees through loyalty redemption mechanics while simultaneously attracting new advertising partners who wanted to associate with the program’s environmental credentials, demonstrating that sustainability rewards can generate commercial value beyond direct member engagement.

4. Carbon Offset Mechanics

Allowing members to use their points currency to fund carbon offset projects is a growing area, particularly in travel and financial services.

Delta SkyMiles has offered members the option to direct points toward carbon offset projects, creating a direct link between travel loyalty and environmental responsibility.

However, carbon offset mechanics are under increasing regulatory scrutiny, and brands operating in this space need to tread carefully.

The Greenwashing Problem: The Risk Every Brand Must Navigate

Sustainability-linked loyalty is not without significant risk. The same consumer awareness that creates the opportunity also creates the threat: customers who care deeply about sustainability are alert to inauthenticity, and the regulatory environment is moving quickly.

Research published in the European Journal of Innovative Studies and Sustainability found that greenwashing has a significant negative impact on consumer trust (β = -0.68) and brand loyalty (β = -0.45), meaning that a sustainability claim that consumers perceive as misleading causes measurable damage to the loyalty relationship, not just to brand reputation.

The regulatory environment is tightening fast with several significant developments have emerged in the past 18 months alone:

  • The UK’s Competition and Markets Authority gained direct fining power of up to 10% of global turnover for misleading green claims in April 2025.
  • Germany’s DWS paid €25 million to prosecutors in April 2025 to settle greenwashing charges.
  • The EU’s Empowering Consumers Directive, taking effect in September 2026, will ban generic environmental claims and offset-based “climate neutral” product marketing across all EU member states.
  • In the US, the FTC’s Green Guides prohibit broad, unqualified environmental claims that consumers cannot verify — and state-level enforcement is strengthening, particularly in California.

For loyalty programs specifically, the implications are significant. Carbon offset claims where brands reward members by purchasing carbon credits on their behalf are under particular scrutiny. Regulators have noted that consumers may interpret these claims to mean that emissions are actually reduced, rather than compensated for through offsets. The EU Empowering Consumers Directive goes further still: from September 2026, offset-based “climate neutral” claims will be prohibited in the EU, regardless of how well they are substantiated.

Brands using carbon offset mechanics in loyalty programs operating in European markets need to reassess their communications strategy urgently.

Best Practice: Building Sustainability Loyalty That’s Authentic

Given both the opportunity and the risk, how should brands approach sustainability-linked loyalty in 2026? The following principles distinguish programs that build genuine brand equity from those that create legal and reputational exposure.

1. Reward verifiable behaviours, not aspirations

The safest and most credible sustainability mechanics are those tied to specific, measurable member actions: bringing a reusable cup, returning a garment, choosing a direct flight over a connecting one. These are actions the brand can verify at the point of transaction, and they produce a clear environmental outcome that can be reported with specificity. Avoid rewarding vague commitments or self-reported behaviours that cannot be authenticated.

2. Be specific about environmental claims

Generic language like “eco-friendly,” “sustainable,” “green” is increasingly both ineffective (consumers are sceptical of it) and legally risky (regulators are moving against it). Replace vague claims with specific, quantified statements: “You helped divert one garment from landfill.” “Your reusable cup choice saved one single-use cup from entering the waste stream today.” Specificity builds credibility. Being vague erodes it.

3. Segment sustainability rewards thoughtfully

Sustainability-linked rewards tend to perform best with member segments that have demonstrated values-aligned behaviour, not as a blanket program feature applied uniformly to the entire membership. Applying eco-rewards broadly without segment targeting typically produces low engagement and no measurable behavioural shift. Identify the members for whom sustainability credentials are genuinely meaningful, and design for them first.

4. Connect the reward to a tangible outcome

The most engaging sustainability mechanics create a visible feedback loop: the member takes an action, and the program shows them the concrete environmental result of that action. Brands are increasingly linking loyalty systems with carbon tracking tools, allowing members to see real-time data on their accumulated environmental impact, trees planted, cups saved, garments kept from landfill. This transparency motivates continued engagement and gives members a shareable achievement, rather than just a points balance.

5. Don’t use sustainability to compensate for an unsustainable business

The most important principle of all. Sustainability loyalty programs that operate as marketing initiatives while the underlying business continues in environmentally harmful practices are exactly what regulators and consumers are now equipped to identify and penalise. The brands whose sustainability programs build genuine loyalty, Patagonia being the most obvious example, are those where the loyalty mechanic is an expression of an authentic operational commitment, not a substitute for one.

The Opportunity

The investment data for 2026 confirms that sustainability in loyalty is moving from consideration to commitment. Approximately 30% of companies plan to implement sustainability-focused initiatives in their loyalty programs in the year ahead — a significant increase from prior years, and a sign that the competitive and reputational case for green loyalty has become sufficiently clear to drive budget allocation.

But the distance between planning to do it and doing it well remains large. The brands that will build genuine competitive advantage through sustainability-linked loyalty are those that treat it as a core program design principle, not a feature bolt-on, and that are willing to make the operational commitments that give those rewards authentic backing.

For loyalty professionals, the strategic questions are now sharper than ever: What sustainable behaviours can your brand genuinely reward and verify? What environmental outcomes can you report with specificity and credibility? And where in your customer base is the appetite for sustainability rewards strong enough to drive meaningful engagement lift?

The answers to those questions are the foundation of a sustainability loyalty program that builds trust rather than eroding it

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ACCC logo

Drawn from the report Loyalty & Reward Co produced for the Australian Competition and Consumer Commission, June 2019.

Almost 80 per cent of Australians belong to at least one loyalty program. That figure, from Mastercard research,1 shows how deeply loyalty programs are woven into Australian consumer life. It does not tell you how much value members actually receive, how the largest programs earn their profits, or what the design choices behind the points mean for competition. Those questions are harder to answer, and until 2019 no one had answered them in public.

In 2019, the Australian Competition and Consumer Commission (ACCC) commissioned Loyalty & Reward Co to produce the first comprehensive, publicly available report on the Australian loyalty industry. The report examined the major programs with more than one million active members, most of them coalition programs, and set out how they are designed, how they are monetised, how they use member data, and what effect they have on competition and on consumers. You can read the full report on the ACCC website. The findings remain a useful reference for anyone designing or operating a program today.

This article summarises what the report found, and what each finding means for program operators.

A market that reaches into almost every industry

Loyalty programs have operated in Australia for several decades and now appear across almost every consumer industry. Estimates of how many programs the average Australian belongs to range from four (Adam Posner, For Love or Money 2018)2 to 6.1 (Mastercard).1 The report concentrated on the four largest coalition programs, Qantas Frequent Flyer, Woolworths Rewards, Velocity Frequent Flyer, and flybuys, because their scale and partner networks give them influence over a large share of Australian spending. A coalition program is one run by a central operator, where a network of partners rewards members with a common currency such as points.

The modern coalition program traces back to 1980, when American Airlines launched AAdvantage, the first frequent flyer program built on a reward currency of miles. Qantas Frequent Flyer followed in 1987 using points. Over the following decades, hotels, banks, supermarkets, and retailers built or joined coalition networks of their own.

Much of the recent history is a contest between two competing partnerships. In 2009, Woolworths partnered with Qantas Frequent Flyer, which grew the supermarket’s member base and gave Qantas a large population of members who rarely flew. Coles took full control of flybuys in 2011 and relaunched it, using cheaper points and supplier-funded bonus offers to compete. When Woolworths relaunched as Woolworths Rewards in October 2015 and replaced Qantas Points with a new currency earned only on selected products, members responded with sustained criticism, and the supermarket reversed much of the change within a year. By 2016, the industry had settled into two camps, Woolworths Rewards with Qantas Frequent Flyer, and flybuys with Velocity.

For operators: a currency change removes something members already value, and members tend to feel that loss more sharply than the gain meant to replace it. The Woolworths experience shows how quickly members react when a redesign reduces perceived value.

The psychology built into program design

The report set out the behavioural research that underpins program design. Several findings are worth knowing.

Operant conditioning (Skinner, 1948)3 holds that behaviour which is reinforced tends to be repeated. Bonus points for a specific action encourage members to repeat it. A related insight is that not all points are equal: the large airline, bank, supermarket, and hotel currencies are desirable enough to change where members choose to shop.

Social identity theory (Tajfel, 1978;4 Bhattacharya and Sen, 2003)5 holds that people fold the brands they identify with into their sense of self. Status tiers apply this directly. A Platinum frequent flyer receives lounge access, priority boarding, and upgrades, and that recognition can build an emotional connection to the airline. Status also raises switching costs, which can keep a member spending even when a competitor charges less for the same product.

The endowed progress effect (Nunes and Drèze, 2006)6 was demonstrated in a car wash study. Members given a card with two of ten stamps already filled redeemed at 34 per cent, against 19 per cent for members given a blank eight-stamp card, even though both groups needed eight stamps. Artificial early progress increased persistence toward the goal.

The goal-gradient effect (Hull, 1934;7 Kivetz, Urminsky, and Zheng, 2006)8 holds that effort increases as a goal comes closer. Members have been observed to accelerate their spending as they approach a status threshold.

Size heuristics describe how one hundred points can feel more rewarding than the one dollar of value it represents. Points let a program present value at a low cost to itself.

Surprise and delight can lift satisfaction well beyond what met expectations achieve. Berman (2005)9 reported that a delighted Mercedes-Benz customer had an 86 per cent likelihood of buying again, against 29 per cent for a merely satisfied one.

For operators: these mechanics work, and that is why they carry a duty of care. Design that manufactures progress or leans heavily on status can drive engagement, and it can also erode trust if members later feel the value was overstated.

How the largest programs earn their profit

A small number of coalition programs are highly profitable. Qantas Loyalty reported revenue of $1,546 million and earnings before interest and tax of $372 million in 2018.10

The report set out the standard coalition model with a worked example. A member spends $1,000 and earns 1,000 points. The program invoices the retailer at around 1.5 cents per point, so the retailer pays $15. When the member later redeems, the program values each point closer to one cent, or $10 for the 1,000 points. The program keeps the difference, roughly $5, a margin of about 33 per cent on that transaction. Across the hundreds of billions of points a large program can sell each year, those half-cents accumulate.

Two further mechanics matter. The first is breakage, the industry term for points that expire unused. Programs set expiry rules, for example 18 months of inactivity for Qantas Frequent Flyer, 24 months for Velocity, and 12 months for flybuys, and higher breakage translates directly into higher profitability. This is why some programs employ actuaries to model it. The second is deferred revenue. A program sets aside enough to cover future redemptions, and a holding of several billion dollars is not unusual for a large Australian coalition program, earning interest in the meantime.

Redemption value also varies by reward. A point redeemed on a flight might be worth one cent, on a gift card half a cent, and on a toaster around 0.25 to 0.35 cents. Pricing steers members toward redemptions that keep cash inside the business.

For operators: breakage and value-steering improve margins, and they sit in tension with member value. A program that optimises breakage too aggressively risks the disengagement that produces breakage in the first place.

The data behind the points

A loyalty program is one of the most effective ways to build a marketing database, because it links transactions to an identified individual over time. The report traced how far that data capability now extends.

Woolworths bought a half-share in analytics firm Quantium in 2013, gaining the ability to turn data from around 8 million loyalty cards into personalised offers. Data exchanges such as Data Republic, backed by Qantas Loyalty, Westpac, NAB, and ANZ, connect a broad network of organisations for secure data sharing. Data brokers can match a single member against tens or hundreds of external datasets, and one broker cited in the report, Rokt, described using billions of user records to personalise offers in real time.

For operators: members increasingly expect transparency and control over their data, a point the report emphasised. A program that collects widely without explaining clearly risks the trust that makes personalisation acceptable in the first place.

The competition question

The report examined whether loyalty programs affect competition, and the evidence points in more than one direction.

Consumer behaviour shows the effect is real. A 2018 Canstar Blue survey found that 21 per cent of shoppers who switched supermarkets did so to earn reward points, and 54 per cent of those who did all their shopping at one supermarket did so because of points.11 International research reaches similar conclusions. Lederman (2003)12 linked frequent flyer enhancements to gains in airline market share, with larger effects at hub airports. Cairns and Galbraith (1990)13 argued that programs raise switching costs and act as a sunk cost that a new entrant must match to compete. McCaughey and Behrens (2011)14 found frequent flyer members in the Netherlands willing to pay a premium of up to 6 per cent. Reichheld (1996)15 found that programs can reduce a member’s sensitivity to competing prices.

The concern is sharpest for smaller companies and new entrants. In a market of dominant duopolies, when the leading players both run large, engaged programs, the competitive tension between them can be neutralised while the barrier facing a new entrant without a comparable program rises. Norway took this seriously enough to ban the earning of points on domestic routes for a period, lifting the ban only in 2013 once domestic competition was judged robust.16

The evidence is not one-sided. Caminal and Claici argued that loyalty pricing can enhance competition by steering business between firms and lowering average transaction prices.17 Aldi, meanwhile, has campaigned directly against points-based programs, arguing that members who chase points routinely spend more, which suggests competitors view those programs as effective.

For operators: a program is a genuine competitive asset, and that same strength invites scrutiny where it raises switching costs or dampens price competition. Designing for real member value, rather than lock-in alone, is the more durable position.

Are members getting what they are promised?

The report closed on the question that matters most to members: the value they actually receive.

Value varies widely. Members of some programs receive as little as half a cent for every dollar spent, while others return 10 per cent or more. Some programs have also reduced value quietly over time. A $100 Barbeques Galore gift card that cost 13,500 points on the Velocity store in 2009 later cost 18,000 points, a 33 per cent increase. A $100 Myer gift card on the Qantas Store rose from 13,500 to 17,770 points, a 31 per cent increase, for a product whose value had not changed. Those increases outpaced the roughly 9.5 per cent inflation over the same five years, and members were not notified.

Some advertising also risks over-promising. The report noted a Qantas credit card campaign using the line “Latte, Latte, Latte, London”. Taken literally, a member would need to buy 20,000 to 40,000 cups of coffee to earn a flight to London, which at one or two cups a day could take up to 55 years. No reasonable consumer would read it literally, and that is the point: broad promotional claims can imply that value is more accessible than it is.

For operators: transparency around expiry, devaluation, and realistic earn rates protects the trust a program depends on. Members forgive a modest return far more readily than a value promise that does not hold up.

What the report means today

Australia’s loyalty industry is sophisticated, profitable, and built on well-understood behavioural science. The ACCC report showed that the same features which make programs effective, the psychology, the data, the coalition scale, and the points economics, are also the features that deserve the most care. A program earns durable loyalty when its design, its data practices, and its promises all hold up to a member reading them closely.

Loyalty & Reward Co produced this report as the loyalty consulting experts, and have since delivered more than 160 loyalty projects for leading brands worldwide. For the full detail, figures, and sources, read the complete report on the ACCC website.

Referencias

Primary source: Shelper, P., Lyons, S., & Savransky, M. (2019). Australian Loyalty Schemes: A Loyalty & Reward Co report for the ACCC. Loyalty & Reward Co. Available at: accc.gov.au

The numbered sources below are cited in the article above. Full footnotes for every industry, media, and program source referenced throughout the report are provided in the ACCC report itself.

  1. Mastercard (2018). Achieving Advocacy and Influence in a Changing Loyalty Landscape.
  2. Posner, A. (2018). For Love or Money 2018, edition 6.
  3. Skinner, B. F. (1948). “Superstition in the pigeon”, Journal of Experimental Psychology, Vol. 38, pp. 168-172.
  4. Tajfel, H., & Turner, J. C. (1978). “An integrative theory of intergroup conflict”, in The Social Psychology of Intergroup Relations, pp. 33-47.
  5. Bhattacharya, C. B., & Sen, S. (2003). “Consumer-company identification: a framework for understanding consumers’ relationships with companies”, Journal of Marketing, Vol. 67, pp. 76-88.
  6. Nunes, J., & Drèze, X. (2006). “The endowed progress effect: how artificial advancement increases effort”, Journal of Consumer Research, Vol. 32, No. 4, pp. 504-512.
  7. Hull, C. L. (1934). “The rat’s speed of locomotion gradient in the approach to food”, Journal of Comparative Psychology, Vol. 17, pp. 393-422.
  8. Kivetz, R., Urminsky, O., & Zheng, Y. (2006). “The goal-gradient hypothesis resurrected: purchase acceleration, illusionary goal progress, and customer retention”, Journal of Marketing Research, Vol. 43, pp. 39-58.
  9. Berman, B. (2005). “How to delight your customers”, California Management Review, Vol. 61, No. 1, pp. 129-151.
  10. Qantas (2018). Qantas Annual Report 2018.
  11. Canstar Blue (2018). Consumer survey on supermarket switching and reward points, as cited in the ACCC report.
  12. Lederman, M. (2003). Do enhancements to loyalty programs affect demand? The impact of international frequent flyer partnerships on domestic airline demand, mimeo, MIT.
  13. Cairns, R., & Galbraith, J. (1990). “Artificial compatibility, barriers to entry, and frequent-flyer programs”, Canadian Journal of Economics, Vol. 23, pp. 807-816.
  14. McCaughey, N., & Behrens, C. (2011). Paying for status? The effect of frequent flyer program member status on airfare choice, Monash University Department of Economics.
  15. Reichheld, F. (1996). The Loyalty Effect: The Hidden Force Behind Growth, Profits and Lasting Value, Harvard Business School Press.
  16. OECD (2014). Airline competition: note by Norway, Directorate for Financial and Enterprise Affairs, Competition Committee.
  17. Caminal, R., & Claici, A. (2007). “Are loyalty-rewarding pricing schemes anti-competitive?”, International Journal of Industrial Organization, Vol. 25, pp. 657-674.
<a href="https://loyaltyrewardco.com/author/kate/" target="_self">Kate Pay</a>

Kate Pay

Kate es Consultora de Estrategia en Loyalty & Reward Co, la consultora líder en fidelización. Loyalty & Reward Co diseña, implementa y opera los mejores programas de fidelización del mundo para las mejores marcas del mundo. Kate ha trabajado anteriormente en funciones de marketing y gestión de cuentas en diversos sectores, como la aviación y los seguros. Kate aplica sus conocimientos a todos los aspectos del negocio, incluido el diseño de programas de fidelización, la estrategia del ciclo de vida, la investigación de mercado y la participación de los socios.

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