If you’ve started researching hearing aids, you might feel like you’ve walked into a maze. There are thousands of devices, endless technical jargon, and a wide variance in prices. It’s enough to make anyone’s head spin.
But here’s the good news: Australia has robust guidelines designed to protect you.
At The Audiology Place in Forestville, we believe that understanding these rules is the first step to making an empowered decision about your health. Let’s break down what the regulations say, what they don’t say, and why our model of independent care is the best way to ensure those guidelines work in your favour.
The Safety Net: Australian Consumer Protection
Hearing aids in Australia aren’t just consumer electronics; they’re medical devices regulated to ensure safety and performance. Between the Australian Government’s Hearing Services Program (HSP), Australian Consumer Law, and ACCC oversight, there’s a comprehensive framework designed to protect your interests.
But like any regulatory framework, it sets minimum standards—and knowing what those standards are (and what they don’t cover) is crucial.
1. Minimum Technical Standards: What Every HSP Device Must Provide
Gone are the days of simple amplifiers. To be approved for subsidy under the Hearing Services Program, hearing aids must meet rigorous specifications outlined in the Hearing Services Program (Voucher) Instrument 2019 and enforced through the Department of Health’s compliance monitoring framework.
This includes:
- Modern styles only: Behind-the-Ear (BTE) and Receiver-in-Canal (RIC) devices are standard. No outdated body-worn aids or basic amplifiers.
- Digital noise reduction: Essential technology to help you hear in complex environments like cafes, restaurants, and social gatherings.
- Rechargeable options: Most devices now offer rechargeable batteries as an alternative to disposables.
- Telehealth capabilities: Many approved devices now support remote adjustments and programming.
- Multiple fitting options: The guidelines insist on client choice—you should never be forced into a “one-size-fits-all” solution.
These standards mean that even “entry-level” fully-subsidised devices are sophisticated medical instruments. That’s a significant win for Australian consumers and a stark contrast to what’s available in many other countries.
2. Transparency on “Preferred Suppliers”: The Hidden World of Commercial Arrangements
This is where the industry can get murky—and where most patients don’t realise what’s happening behind the scenes.
The ACCC (Australian Competition and Consumer Commission) actively enforces rules against misleading sales and hidden commissions. Meanwhile, the Hearing Services Program requires all contracted providers to disclose their commercial arrangements with device manufacturers.
Under Section 28 of the HSP Voucher Instrument and Clause 9.5 of the Service Provider Contract, providers must inform you in writing about:
- Whether they receive direct or indirect benefits (financial or otherwise) related to device purchases—including exclusive supply arrangements, price discounts, commissions, gifts, and rewards
- Whether the devices are manufactured or supplied by a related party
- Whether the provider is also an appointed supplier and supplies their own devices
Sounds comprehensive, right?
Here’s the catch: The disclosure requirements are minimal. Providers only need to state whether arrangements exist—they don’t have to provide details. A clinic could have a poster saying “We have preferred supplier arrangements with some manufacturers” and technically be compliant.
What patients don’t always realise is how common and how significant these arrangements can be:
Common Industry Practices (That Aren’t Always Disclosed in Detail):
- Manufacturer ownership: Many clinics in Australia are owned by hearing aid manufacturers. In fact, several of the largest audiology chains are wholly-owned subsidiaries of device companies. This creates an inherent “preferred supplier” bias.
- Sales commissions and bonuses: Staff members receiving financial incentives for selling particular brands or achieving sales targets—especially for partially-subsidised (“top-up”) devices.
- Volume rebates and rewards programs: Clinics receive bonuses for hitting sales targets with specific manufacturers.
- Marketing support and equipment loans: Manufacturers providing funding for clinic fit-outs, equipment, branding, or marketing in exchange for preferential treatment.
- Conference sponsorships and “education”: Overseas trips, conference attendance, and training events funded by manufacturers to build loyalty.
- Exclusive supply agreements: Contracts limiting which brands can be offered to meet volume commitments.
None of these arrangements is illegal, and many practitioners still provide excellent care despite them. But they do create conflicts of interest that can materially affect the recommendations you receive.
The Real-World Impact:
Imagine you’re fitted with your hearing loss pattern and lifestyle needs. An independent audiologist has access to devices from Phonak, Oticon, Widex, Starkey, Signia, ReSound, and others. They can objectively assess which technology suits you best.
Sonova owns Connect Hearing, Triton Hearing, Hearing Planet, and Blamey Saunders Hears, stocking Phonak, Unitron, Lyric, and Advanced Bionics cochlear implants.
These chains operate hundreds of clinics nationwide, often with sales incentives tied to Sonova devices.
Demant Holdings controls Audika and HearingLife (formerly AudioClinic), selling Oticon, Bernafon, Sonic, and Philips hearing aids across over 400 Australian sites.
The ACCC fined Demant subsidiaries $2.5 million in 2018 for misleading pensioner ads under these brands.
Amplifon runs Amplifon and National Hearing Care (formerly standalone), rebranding devices from various makers under their label without manufacturing.
This network spans over 300 clinics, prioritising volume sales.
WS Audiology (Denmark) owns Bloom Hearing with Widex, Signia, and Rexton.
Non-manufacturer retailers such as Specsavers (Advance aids) and Costco (Kirkland) also operate clinics that use private-label devices.
Do you think the recommendation might be different?
The research suggests it is. Studies on prescribing behaviour consistently show that financial incentives influence clinical decisions, even when practitioners believe they’re being objective.
3. Strict Rules on Replacements: Stopping Unnecessary Sales
To prevent unnecessary sales, regulations under Section 76 of the HSP Schedule of Service Items and Fees prohibit replacing hearing aids without clinical justification.
Legitimate reasons include:
- Significant change in your hearing requiring different technology
- Device damaged beyond repair (with proper documentation)
- Meeting specific Eligibility Criteria for Refitting (ECR)
What shouldn’t happen: A clinic pushing you to upgrade every two years simply because your subsidy is available again, when your current devices are working perfectly well.
The compliance monitoring framework actively audits providers to ensure replacements and refits meet program requirements. This includes checking that proper documentation exists, that Minimum Hearing Loss Thresholds are met, and that clients genuinely need new devices.
4. What the Guidelines Don’t Tell You
While Australia’s regulatory framework is strong, there are limits to what it can control:
- Quality of clinical assessment: The regulations ensure devices meet minimum standards, but they don’t dictate how thoroughly your hearing is assessed. A 15-minute appointment with a free audiogram is very different from a comprehensive assessment, which includes tympanometry, extended high-frequency testing, speech-in-noise testing, and evaluation for conditions such as tinnitus or auditory processing issues.
- Device selection within brands: Even if a clinic discloses it has “arrangements” with manufacturers, it may still have wide latitude in recommending specific models within those brands—often the ones with the highest margins.
- Aftercare quality: The regulations don’t prescribe how much follow-up care you receive, how accessible your audiologist is for adjustments, or how thoroughly they work with you to optimise your devices.
- Private purchase pressure: While there are protections for HSP devices, the regulations are less specific about how clinics present private purchase options and partially subsidised devices to clients.
The Audiology Place Difference: Independence in Action
While these guidelines set the minimum standard for the industry, at The Audiology Place, we aim for the gold standard.
We operate as a fully independent audiology practice. A manufacturer does not own us, and we’re not part of a large retail chain. This independence isn’t just a badge we wear; it’s the foundation of your clinical care.
We Work for You, Not a Manufacturer
Because we’re unaffiliated, we have no “preferred supplier” list. We recommend devices based purely on your clinical needs and your physiology.
- Need the superior connectivity of Phonak? We can fit it.
- Is the sound quality of Oticon’s BrainHearing technology better suited to your listening environments? We can prescribe it.
- Does Starkey offer the specific features you need? We have access to it.
- Would Widex’s naturalness of sound be ideal for your music appreciation? We can provide it.
- Is ReSound’s Android streaming capability important for your lifestyle? We can fit it.
We’re genuinely brand-agnostic because we have no financial reason to be otherwise.
Zero Conflicts of Interest
Let’s be completely transparent about our commercial arrangements (as required by the HSP regulations):
- Manufacturer relationships: We purchase devices from authorised suppliers at standard trade prices. We receive no volume bonuses or other incentives beyond normal margins.
- Staff compensation: Our practitioners receive a salary. Their income is not tied to device sales, brands sold, or revenue generated. There are no commissions, bonuses, or sales targets.
- Ownership structure: The Audiology Place is privately owned by Dr. Signe Steers, a practising audiologist. We’re not affiliated with any manufacturer, corporate network, or retail chain.
- Brand availability: We can fit you with any hearing aid brand available through the Hearing Services Program that suits your hearing loss and preferences.
This isn’t just about compliance with regulations—it’s about removing every possible bias from your care.
Are All Brands Really the Same?
We need to be honest with you: not all hearing aid brands are equal.
While we can fit you with any brand you request, some manufacturers genuinely have superior technology, better sound processing, more advanced features, and more reliable performance. This is particularly true at the premium end of the market.
Some brands excel at speech understanding in noise. Others have superior connectivity. Some are more reliable. Some are better for particular types of hearing loss patterns.
The difference is that our recommendation is based on:
- Your specific hearing loss pattern and which technology addresses it best
- Your listening environments and which features you’ll actually benefit from
- Your budget and values—whether fully-subsidised devices meet your needs or whether premium features are worth the investment for your lifestyle
- Objective performance data and our clinical experience with different manufacturers
- Your preferences regarding size, aesthetics, rechargeability, and connectivity
We’ll tell you honestly which brands and models we think are best for your situation and why. If a fully-subsidised device will meet your needs perfectly, we’ll let you know that. If premium technology would give you significantly better outcomes, we’ll explain the differences so you can make an informed choice.
What we won’t do is push you toward a particular brand because it benefits us financially.
Clinical Depth Over Retail Breadth
Our independence allows us to focus on complex diagnostics that retail chains often skip or rush through.
This includes:
- Comprehensive diagnostic assessments: Not just a free audiogram, but tympanometry to assess middle ear function, extended high-frequency testing, speech-in-noise evaluation, and thorough case history.
- Differential diagnosis: Identifying whether your hearing difficulties are purely sensory hearing loss or involve other factors like auditory processing, cognitive load, or middle ear pathology.
- Specialist conditions: Thorough assessment and management of tinnitus, hyperacusis, misophonia, and other auditory conditions that affect quality of life.
- Medical referral pathways: Knowing when to refer to ENT specialists, neurologists, or other medical professionals—and actually doing so rather than just fitting devices.
- Real-ear measurement: Objective verification that your devices are providing the correct amplification for your specific hearing loss.
We treat hearing health as a complex medical picture, not a sales opportunity.
The Compliance Framework Works Better When the Incentives Align
The Australian Government’s Compliance Monitoring and Support Framework for the Hearing Services Program includes regular audits, claim reviews, self-assessments, and complaint investigations.
Providers are audited on:
- Whether clients meet Minimum Hearing Loss Thresholds before fitting
- Whether replacements and refits are clinically justified
- Whether qualified practitioners deliver services
- Whether claims are accurate and substantiated
- Whether device supply arrangements are properly disclosed
This framework works well to catch egregious violations. But it works even better when the provider’s incentives naturally align with the program’s goals.
When there are no sales targets to meet, no commissions to earn, and no volume bonuses at stake, compliance isn’t a burden—it’s simply how we operate.
How to Identify Conflicts of Interest at Other Clinics
If you’re comparing clinics (which you should!), here are some questions that might reveal conflicts of interest:
- “Do your practitioners receive commissions, bonuses, or any financial incentives for selling hearing aids or particular brands?”
- “Do you have sales targets that staff are expected to meet?”
- “Do you receive any benefits from hearing aid manufacturers beyond standard wholesale pricing—such as rewards programs, equipment loans, marketing support, or conference sponsorships?”
- “Are you owned by, or affiliated with, any hearing aid manufacturer or corporate network?”
- “Can you fit me with any brand of hearing aid available through the Hearing Services Program, or are you limited to certain manufacturers?”
- “Do you have an exclusive or preferred supply arrangement with any manufacturers?”
- “How do you decide which brand and model to recommend to me?”
If you get vague answers, deflection, or defensiveness to these questions, that might tell you something important.
Red Flags to Watch For:
- Being shown only one or two brands without an explanation of why others weren’t considered
- Pressure to purchase partially-subsidised devices when you haven’t been given a genuine comparison with fully-subsidised options
- Claims that a particular brand is “the best” without reference to your specific hearing loss and needs
- Reluctance to provide device comparisons or explain specific features
- High-pressure sales tactics or limited-time offers
- Being told you need to upgrade when your current devices are working well
The Bottom Line
Australian guidelines are there to protect you from misleading sales and substandard technology. The Hearing Services Program’s compliance framework, ACCC oversight, and disclosure requirements create a strong foundation for patient protection.
But the best way to ensure you’re getting truly unbiased advice is to choose a provider who has no reason to be biased in the first place.
At The Audiology Place, we’ve built our practice around a simple principle: we recommend what we would want for our own family members.
That means:
- No sales pressure
- No upselling
- No commissions
- No conflicts of interest
- Transparent pricing
- Multi-brand trials when appropriate
- Commitment to current technology
- Comprehensive diagnostic assessment
- Genuine, long-term relationships with our patients
We can’t control what other clinics do, but we can control what we do. And we’ve chosen to structure our practice in a way that puts your hearing health first—not just because the regulations require it, but because it’s the right thing to do.

