On the weekend of 24 July 2026, more than 30 Consumer Affairs Victoria (CAV) inspectors fanned out across auctions in Merri-bek and Darebin. They weren’t responding to complaints. They were just there, watching campaigns run, talking to agents about their obligations and talking to buyers about their rights.
For agency principals, that detail is the whole story. Regulators aren’t waiting for a complaint before they turn up any more.
The short version
- Victoria’s Underquoting Taskforce has attended more than 500 auctions and issued more than 260 fines since 2022, and a third of its complaints come from competing agents.
- Underquoting carries a maximum of 240 penalty units, a little over $50,000, plus possible loss of commission.
- Inspectors don’t ask what you believed. They ask to see the records that show how you decided.
- Trust accounting works the same way. Victorian audits for the year to 30 June have to be completed and lodged by 30 September.
- Compliance culture can’t be inspected. The records it leaves behind can.
The taskforce, by the numbers
Victoria’s Underquoting Taskforce was set up in 2022. CAV says that since then it has:
- monitored more than 3,200 sales campaigns
- attended more than 500 auctions
- issued more than 400 official warnings
- issued more than 260 fines, totalling around $3 million
- received more than 8,800 complaints through its dedicated web form
That last figure has a sting in it. CAV Director Nicole Rich has said roughly one in three of those complaints came from competing estate agents. Your compliance record isn’t only being assessed by a regulator with limited resources. It’s being watched, in real time, by every other agency working the same streets, and a fair few of them are willing to pick up the phone.
The taskforce is also prepared to go to court. Former Glen Waverley agency Harcourts Judd White and three of its representatives are facing court over multiple alleged underquoting breaches.
Rich’s summary of the winter blitz was positive on its face: “We know most agents want to do the right thing and it was pleasing to see well-run auctions over the weekend.” That’s a fair description of the industry. It’s also a reminder that “most agents” is the benchmark the exceptions get measured against.
What’s actually being checked
Underquoting enforcement in Victoria rests on the Statement of Information. For every residential sales campaign, agents have to prepare an approved Statement of Information, display it at every open for inspection and include it with online advertising. It has to show an indicative selling price, either a single figure or a range no wider than 10 per cent, the three most comparable sold properties, and the suburb’s median house or unit price.
The comparables are where campaigns come undone. The properties have to be of a similar standard or condition, sold within six months and within two kilometres in metropolitan Melbourne (18 months and five kilometres outside it). Agents have to use all the sales data available to them and can’t hide behind confidentiality arrangements. Qualifying terms like “offers above”, “from” or a trailing ”+” aren’t allowed, and an advertised price can’t sit below the estimated selling price, the vendor’s asking price, or a written offer already rejected.
The consequences aren’t small. Under the Estate Agents Act 1980, underquoting carries a maximum of 240 penalty units, a little over $50,000 at the 2026-27 penalty unit value of $209.10. Agents also risk forfeiting sales commission, in serious cases all of it. CAV points to Australian Consumer Law exposure as well, where maximum penalties doubled on 28 March 2026: for corporations, the greater of $100 million, three times the benefit obtained, or 30 per cent of adjusted turnover, and $2.5 million for individuals.
And more has now arrived. The Consumer Legislation Amendment Act 2026 passed in September 2026. From 1 October, agents have to publish the vendor’s reserve price at least seven days before an auction or fixed-date sale, with marketing material updated to match. We’ve set out what changes and when in a separate article.
What this means for every agency, in every state
Here’s the part that matters beyond Victoria’s sales desks.
The Underquoting Taskforce shows how regulators across Australia and New Zealand increasingly work. Field inspections rather than complaint-driven audits. A public reporting channel that makes it easy to dob in a competitor. Published enforcement statistics that signal intent. And a standard of proof that assumes you can produce your working.
That last one is what most agencies underestimate. An inspector at an auction isn’t asking whether you believed the price range was fair. They’re asking to see how you picked your comparables and what records you kept. The test is what you can show, not what you meant.
Trust accounting runs on exactly the same logic, and Victorian agencies are in the middle of that cycle right now. Estate agent trust accounts have to be audited for the financial year ended 30 June, with the audit completed within three months and the report lodged through myCAV within 10 business days of receiving it from the auditor. Failing to lodge is an offence carrying up to 120 penalty units, a little over $25,000. Our Victorian trust accounting page sets out the full requirements.
Auditors have their own reporting duty, too. If they find accounts that can’t be properly audited, evidence of dishonesty, a deficiency in trust funds, or non-compliance with the legislation, they have to notify CAV directly. Your auditor isn’t only your adviser. In defined circumstances, they’re a mandatory reporter.
Five questions worth asking before 30 September
If the auction blitz prompts one internal conversation this month, make it this one:
- Could we reconstruct any campaign from the last 12 months? Comparable selections, the reasoning behind them, and every version of the Statement of Information, retrievable rather than remembered.
- Is our advertising checked before it goes live, or after someone complains? Price ranges, qualifying language and post-rejection updates are the usual failure points.
- Are our trust account reconciliations current, or are we relying on the audit to find the gaps? An adverse finding almost always has a paper trail that predates it by months. Our audit red flags article lists the usual suspects.
- Who owns the 30 September deadline? In agencies without a named owner, audit lodgement is the obligation most likely to be missed entirely. Our compliance calendar puts every date in one place.
- Would a competitor find anything worth reporting? Given a third of taskforce complaints come from inside the industry, that’s a practical test, not a rhetorical one.
Compliance culture isn’t something a regulator can inspect directly. What they can inspect is the record it leaves behind. Thirty inspectors on a Melbourne winter weekend are a reminder that the record needs to be ready before anyone asks for it.
We provide outsourced trust accounting, compliance and bookkeeping for real estate agencies across Australia and New Zealand, including reconciliation, audit preparation and lodgement support. If you’d like a second set of eyes on your trust account before your Victorian audit deadline lands, get in touch.
Sources: Melbourne’s inner north targeted in winter auction compliance checks (24 July 2026), Underquoting information for real estate agents and Auditing estate agents trust accounts, Consumer Affairs Victoria; Bringing The Hammer Down On Underquoting, Premier of Victoria (20 November 2025); Penalties and values, Department of Justice and Community Safety Victoria; and Fines and penalties, ACCC. This article is general information for agencies, not legal advice.