---
title: "Competition law compliance policy for algorithmic and AI pricing tools"
url: "https://ailawframework.com/precedents/competition-and-consumer-law/algorithmic-pricing-compliance-policy"
type: "precedent"
site: "AI Law Framework"
id: "a29-algorithmic-pricing-compliance-policy"
area_id: "A29"
kind: "policy"
ai_level: "yellow"
version: 1
law_stated_as_at: "2026-10-17"
---

# Competition law compliance policy for algorithmic and AI pricing tools

> Policy that controls how a business selects, configures and monitors pricing software and AI tools so they do not share competitors' sensitive information, coordinate prices or mislead customers, with approval, data,…

Canonical page: https://ailawframework.com/precedents/competition-and-consumer-law/algorithmic-pricing-compliance-policy  
Law stated as at: 2026-10-17

Site index for agents: https://ailawframework.com/llms.txt

Policy that controls how a business selects, configures and monitors pricing software and AI tools so they do not share competitors' sensitive information, coordinate prices or mislead customers, with approval, data, audit and escalation rules.

## Key facts

- Kind: Policy. A policy or procedure for a firm or client.
- Practice area: [Competition & Consumer Law](https://ailawframework.com/precedents/competition-and-consumer-law.md)
- Jurisdictions: Australia, European Union, United States
- AI level: Yellow. AI can help in set ways. A lawyer checks specific points before use.
- Law stated as at: 2026-10-17
- Status: Maintained. Checked on 2026-10-17 against the 8 authorities it cites, for Australia, European Union and United States.

## When to use it

Use for any business that uses third-party or in-house software to set, recommend or adjust prices, discounts, rents, bids or supply levels, especially software also used by competitors. Do not use as a substitute for advice on a specific pricing tool or industry arrangement.

## How AI may be used

Close supervision. AI can map a pricing tool's features and data flows against the risk list in this policy, but whether an arrangement or practice is a cartel provision or concerted practice is a competition lawyer's judgment, and the business stays liable for what its tool does.

**AI may:**

- Extract from vendor contracts and technical documents what data the tool collects, from whom, how it is pooled and what outputs it gives.
- Draft the tool register entry and the risk questionnaire answers for review.
- Monitor pricing outputs for the red flags listed in clause 8 and report exceptions.

**AI must not:**

- Must not conclude that a tool or arrangement is lawful.
- Must not be used to obtain, infer or share competitors' current or future prices or strategies.
- Must not be configured or prompted to align prices with competitors or to respond to signals from them.

**The lawyer checks:**

- Each pricing tool has been reviewed and approved under clause 5 before use.
- Data inputs do not include competitors' non-public information, directly or through a vendor's pooled data.
- Delegation of pricing decisions to a vendor or common platform does not create an arrangement or understanding with competitors.
- Personalised pricing is disclosed where required and not misleading.

## Authorities

- [Competition and Consumer Act 2010 (Cth) ss 45AD, 45AF, 45AG, 45AJ, 45AK (cartel provisions, offences and civil penalties)](https://www.legislation.gov.au/C2004A00109/latest/text)
- [Competition and Consumer Act 2010 (Cth) s 45(1)(c) (concerted practices) and s 46 (misuse of market power)](https://www.legislation.gov.au/C2004A00109/latest/text)
- [Competition and Consumer Act 2010 (Cth) s 76 (pecuniary penalties)](https://www.legislation.gov.au/C2004A00109/latest/text)
- [Australian Consumer Law (Competition and Consumer Act 2010 (Cth) Sch 2) ss 18, 29(1)(i)](https://www.legislation.gov.au/C2004A00109/latest/text)
- [Privacy Act 1988 (Cth) Sch 1 APP 1.7-1.9 (automated decisions in privacy policies, from 10 December 2026)](https://www.legislation.gov.au/C2004A03712/latest/text)
- [Treaty on the Functioning of the European Union art 101 (EU)](https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=CELEX:12008E101)
- [Sherman Act, 15 U.S.C. s 1 (US)](https://www.govinfo.gov/link/uscode/15/1?link-type=html)
- [US Department of Justice, proposed settlement with RealPage Inc. (24 November 2025)](https://www.justice.gov/opa/pr/justice-department-requires-realpage-end-sharing-competitively-sensitive-information-and)

## Full text and drafting notes

The full text and the drafting notes are not part of this public page. Signed-in firm accounts can read them at https://ailawframework.com/precedents/competition-and-consumer-law/algorithmic-pricing-compliance-policy and through the signed-in MCP connector https://ailawframework.com/mcp/firm.

*Practice guidance for planning and review. Confirm current primary sources and the requirements of the actual matter. This is general information, not legal advice.*