A fall on an escalator
A guest loaded with bags falls on an escalator at an outlet centre. The centre owes care for its premises, but if your guide rushed the group to make the coach, part of the claim can point at you.
TOUR OPERATOR INSURANCE
Shopping Tour Insurance
Outlet trips, market mornings and retail precincts, sometimes overseas. The physical risk is modest. The questions are about money: who pays you, what you tell guests, and what happens to their purchases.
$20MPublic liability limit available
PI + PLProfessional indemnity and public liability, together or on separate policies
CommissionsIf retailers pay you, disclosure is part of the underwriting
Premiums and outcomes described are specific to this client and indicative only. Your own terms will depend on your circumstances and the insurer.
THE SHORT ANSWER
What insurance does a shopping tour business need in Australia?
A shopping tour operator generally needs public liability for injury to guests and damage to property, and professional indemnity for errors and advice in your professional services. The physical risks are modest: crowds, escalators and bags. What's specific to shopping tours is money and advice. If retailers pay you commissions, tell guests and the underwriter, because the PI section of at least one wording we place can exclude claims where you had a financial interest in the transaction beyond your fees, unless it was acknowledged in writing. Advice on customs allowances or tourist refunds is professional advice. Purchases you mind for guests are property in your care, custody or control. Shopping tours are a tour type the specialist markets we approach are set up to quote, subject to each insurer's assessment.
Misleading claims about products or prices are an Australian Consumer Law matter. Fines and penalties are excluded from public liability, though PI can respond to some consumer law claims for compensation. General information only. It doesn't take into account your objectives, financial situation or needs, and it isn't legal advice.
- Core covers
- Public liability and PI
- Commissions
- Disclose them to guests and the underwriter
- Advice
- Customs and refund tips are professional advice
- Watch for
- Lost purchases, conflicts of interest, overseas trips
An undisclosed commission
A guest finds out the shop you recommended paid you a commission, and says the price was inflated and the advice wasn't in their interest. That's a misleading conduct and PI question, and an undisclosed interest can take it outside PI.
Wrong customs advice
Your guide tells a group returning from overseas that their purchases are within the duty-free allowance, and they're charged at the border. A claim for that loss is a PI claim for your advice.
Bags left on the coach
Purchases stored on the coach while the group visits another store go missing. Property in your care, custody or control is excluded from public liability except for a limited extension, so check before you offer to mind bags.
A faulty or fake product
A guest buys something on your tour that turns out to be faulty or not what the label said. The retailer is the supplier. If you sold or supplied it yourself, it's your product, and claims you made about it are your responsibility.
A market day lost overseas
An outbound shopping tour loses a day when a market closes for a holiday you missed or a transfer doesn't show. Guests' extra costs from your booking error are a PI question. The tour price itself isn't refunded by PI.
| Situation | Cover that may respond | What to know |
|---|---|---|
| Guest falls in a shopping centre or market during the tour | Public liability can respond | Where the centre's premises were at fault, its own cover may respond. A claim can name both. |
| Guest claims your retailer recommendation was a conflict of interest | Professional indemnity, subject to disclosure | The PI section of at least one wording we place excludes claims where you had a financial interest beyond your fees, unless acknowledged in writing. Raise commissions with the underwriter. See professional indemnity for tour operators. |
| Wrong advice on duty, customs or tourist refunds | Professional indemnity can respond | Can respond as professional services only if your schedule describes that advice. Claims made basis. |
| Guests' purchases lost or damaged while you hold them | Limited public liability extension | Care, custody or control is excluded, with a limited write-back for visitors' personal effects and property temporarily in your control. |
| Guest injured on the coach between centres | CTP scheme, which may respond, and the coach operator's cover | The tour operator policies we arrange exclude injury caused by a registered vehicle from public liability. The state CTP scheme may respond, but in Queensland, WA and SA it depends on fault, so an injury can fall between the two. See vehicles and passenger liability. |
| Penalty for misleading advertising or pricing | Excluded from public liability | Fines and penalties are excluded from public liability on the tour operator policies we arrange. On at least one wording we place, the PI section has a sub-limited statutory liability extension for some penalties that are insurable at law, and some WHS penalties cannot lawfully be insured. Ask us how PI treats consumer law claims before you rely on it. |
- Where you take guests: outlet centres, markets, retail precincts, and any overseas destinations
- Whether retailers pay you commissions or referral fees, and how you disclose them to guests
- Whether you own, or have a financial interest in, any shop you visit
- What your guides tell guests about duty-free allowances, customs, GST or tourist refunds
- Whether you store, carry or ship guests' purchases
- Whether you sell products to guests yourself, and where they come from
- Transport between stops, and who provides it
- Annual revenue, years operating and any claims or incidents
Undisclosed financial interests
Claims where you had a financial interest in the transaction beyond your fees can be excluded from PI unless it was acknowledged in writing. Disclose commissions up front.
Fines and penalties
Penalties for misleading conduct or pricing are excluded from public liability on the tour operator policies we arrange, and on at least one wording we place the PI statutory liability extension is sub-limited. Clear disclosure and accurate claims about products are the controls.
Supplier collapse
If a retailer, freight company or wholesaler you've used goes broke, supplier insolvency is generally excluded from PI on the tour operator policies we arrange.
Imported goods you sell
If you import and sell products yourself, products that don't meet Australian standards are excluded on at least one wording we place.
At least one specialist tour operator wording we place excludes injury from a list of adventure activities, including horse riding, e-bikes and Segways, surfing and scuba diving, and white water rafting. See the adventure activities excluded on one wording we place, grouped, and check the endorsement on your own schedule.
Commissions. Being paid by the shops you visit changes how your recommendations look. If a guest later says you steered them to overpriced goods, the claim is about misleading conduct and conflict of interest. The PI section of at least one wording we place excludes claims where the operator had a financial interest in the transaction other than its fees, unless a signed acknowledgement was obtained. Whether retailer commissions count isn't spelled out in that wording, so raise them with the underwriter and disclose them to guests in writing.
Advice on duty, GST and refunds. Guides on shopping tours field questions about duty-free allowances, customs declarations and tourist refunds. A wrong answer can cost guests money at the border, and that's a professional indemnity question. PI can respond to civil liability from the professional services on your schedule, so describe the advice you give. Better still, point guests to the official Australian Border Force information rather than quoting allowances yourself.
Purchases in your hands. Minding bags on the coach, carrying parcels or arranging shipping puts guests' property in your care, custody or control. Public liability excludes that property except for a limited extension for visitors' personal effects and other property temporarily in your control. If you ship purchases home for guests, the freight company's terms and insurance matter, and supplier insolvency is excluded from PI.
Queensland regulates shopping on inbound tours. The Tourism Services Act 2003 (Qld) sets up a registration system for inbound tour operators, meaning businesses that sell travel packages including Queensland travel to overseas wholesalers, retailers or corporate buyers for an inclusive price. Registration is needed where at least 20% of the packages you sold in the last 12 months were Queensland-based tours for overseas travellers. A mandatory code of conduct bans controlled shopping, overcharging and high-pressure tactics, and requires quotes to show the total package cost. Tour guides aren't registered, but they must not stop a tourist shopping elsewhere or withhold a tourist's money, passport or documents, and the Act prohibits unconscionable conduct by operators and guides alike. Operating unregistered carries a maximum penalty of $34,540 for an individual, as at October 2026, and corporations can face up to five times that. Fines and penalties are excluded from public liability on the tour operator policies we arrange. On at least one wording we place, the PI section has a sub-limited statutory liability extension for some penalties that are insurable at law, and some WHS penalties cannot lawfully be insured. For overseas shopping trips, see insurance for overseas tours.
| Who asks | What they ask for | What to know |
|---|---|---|
| Queensland Office of Fair Trading | Registration as an inbound tour operator before you sell Queensland-based packages to overseas wholesalers, retailers or corporate buyers | Needed where at least 20% of the packages you sold in the last 12 months were Queensland tours for overseas travellers. Applicants need a criminal history check, and processing takes four to six weeks. |
| Queensland's code of conduct for inbound tour operators | A written dispute resolution policy, quotes showing the total package cost, and records kept: financial records for seven years, and itineraries, quotes and promotions for two | The code is mandatory for every inbound tour operator. It bans controlled shopping and overcharging, such as charging entry to a free attraction. |
| Queensland tour guides | Identification on display showing the guide's full name and business address, a recent colour photo, and the operator's name | Guides aren't registered under the Act, but its conduct rules and the ban on unconscionable conduct apply to them. |
| Viator | Valid public liability insurance, a mandatory global baseline from its August 2026 supplier agreement | Viator sets the minimum by activity risk and destination. Expired or insufficient documents freeze new sales until updated ones are approved. |
Fake Aboriginal souvenirs sold through tourist shops: ACCC v Birubi Art (Federal Court, 2019)
A wholesaler sold 49,493 boomerangs, didgeridoos and similar items to shops in tourist areas. They were made in Indonesia and carried claims such as "Authentic Aboriginal Art". The Federal Court found the representations false or misleading and in June 2019 ordered a $2.3 million penalty. The wholesaler wasn't a tour operator. The case is here because the goods were sold through the kind of shops a shopping tour visits.
The insurance lesson. If your guides repeat a retailer's authenticity claim, or you sell souvenirs yourself, the claim becomes yours. Ask retailers how they can show where their goods come from, and keep your guides' product talk factual.
Source: ACCC media release: $2.3M penalty for fake Indigenous Australian art
Disclose commissions in writing
State in your booking terms, and again on the day, which retailers pay you a commission or referral fee. Keep a list of those arrangements for the underwriter.
No controlled shopping
Guests choose where they shop and for how long. Queensland's code for inbound tour operators bans controlled shopping and high-pressure tactics, and it's a sound rule for any shopping tour.
Ask retailers about provenance
For art, souvenirs, opals, wool and similar goods, ask how the retailer can show where the product was made. Don't put a shop on the itinerary if it can't.
Point to the official source on duty and refunds
Give guests the Australian Border Force link in the pre-tour email and tell guides not to quote allowances from memory. If you do give that advice, describe it to the underwriter.
A bag rule
Decide whether purchases stay with guests or on the coach. If the coach is the store room, it's locked, someone is responsible for it, and guests are told what you will and won't answer for.
Keep itineraries, quotes and complaints
Hold your itineraries, quotes and promotional material, and a written record of each complaint and how you resolved it. Queensland's code sets minimum periods for inbound operators, and a PI claim will ask for the same documents.
We've found tour operator public liability hard to place on its own in the past, and PI and public liability often had to be split across insurers. We approach several specialist insurers and underwriting agencies. Some write PI and public liability together, others write one or the other, and we put the cover together to suit the tours you run, for tour operators and for travel agents that run their own tours, subject to each insurer's assessment.
We don't publish a separate price for shopping tours. As a general guide, across the tour types the markets we approach are set up to quote, subject to each insurer's assessment, combined PI and public liability for a small tour operator costs approximately $1,200 to $1,800 a year including fees. As at October 2026. Your price depends on the activities, destinations, revenue, limits and claims history, and it can fall outside that range. It is not a quote. See what drives the premium.
A placement from September 2026. A new NSW-based cultural tour operator designs immersive programs for groups visiting Australia and for Australian groups visiting Asia, with local tour companies running the coaches and accommodation. It needed a certificate of currency urgently. Result: $20 million public liability and $1 million professional indemnity on one combined policy, worldwide territory excluding US jurisdiction, placed the same week on that occasion at approximately $1,850 including fees. This is one past placement, not a quote. Your price and terms depend on your risk. Read the case study.
Sources referred to on this page
- Tourism Services Act 2003 (Qld)
- Queensland Government: register as an inbound tourism operator
- Queensland Government: work in the inbound tour industry
- Queensland Government: inbound tour operators, breaches and penalties
- ACCC: $2.3M penalty for fake Indigenous Australian art
- Viator: updated supplier agreement, August 2026
FREQUENTLY ASKED QUESTIONS
Shopping Tour Insurance FAQs
Tell them, and tell the underwriter. Undisclosed commissions invite misleading conduct complaints under the Australian Consumer Law, and the PI section of at least one wording we place excludes claims where you had a financial interest in the transaction beyond your fees, unless acknowledged in writing. Clear disclosure in your booking terms and on the day helps protect your guests, and raising commissions with the underwriter helps protect your cover.
It can be, under professional indemnity, if the advice is part of the professional services described on your schedule. PI is claims made, so the claim must be made and reported while the policy is in force. The safer path is to point guests to the official Australian Border Force information rather than quoting allowances yourself.
Property in your care, custody or control is excluded from public liability on the tour operator policies we arrange, with a limited extension for visitors' personal effects and property temporarily in your control. Guests' own travel or contents insurance may also respond. If you mind bags or ship purchases, tell the underwriter and set clear rules in your terms.
The same cover can apply, but the questions widen. Overseas tours are within the appetite of the specialist markets we approach, subject to each insurer's assessment. On at least one wording we place, the territory is worldwide and claims in US courts are excluded. That wording requires reasonable steps so every guest holds comprehensive travel insurance, and excludes destinations rated Do Not Travel before the tour starts.
The retailer that sold it is the supplier. You come into it if you sold or supplied the item yourself, or made claims about it to guests. Products you supply come under products liability, subject to the wording, but fines and penalties are excluded from public liability on the tour operator policies we arrange. Keep your guides' product talk factual and let the retailer make the claims.
You do if you sell travel packages that include Queensland travel to overseas wholesalers, retailers or corporate buyers, and at least 20% of the packages you sold in the last 12 months were Queensland-based tours for overseas travellers. Registration is with the Office of Fair Trading and comes before you sell. Operating unregistered carries a maximum penalty of $34,540 for an individual, as at October 2026. Working only as a tour guide doesn't need registration.
Not in Queensland. The code of conduct for inbound tour operators is mandatory and bans controlled shopping, overcharging and high-pressure tactics. Tour guides must not stop a tourist from shopping elsewhere or withhold a tourist's money, passport or documents, and the Tourism Services Act prohibits unconscionable conduct. Penalties under the Act are excluded from public liability on the tour operator policies we arrange, and you shouldn't assume a compensation order is covered, so the control is how you run the day.
We don't publish a separate price for shopping tour insurance. As a general guide, combined professional indemnity and public liability for a small tour operator costs approximately $1,200 to $1,800 a year including fees, as at October 2026, and it can fall outside that range. Overseas destinations, commission arrangements, product sales and revenue move the price. Any vehicles you own need their own motor cover, priced separately. It is not a quote.
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QUOTE REQUEST
Get a Shopping Tour Insurance Quote
Tell us the tours you run, where they go, group sizes, who supplies transport and venues, your annual revenue, and the limit you need on your certificate.
Specialist broker review Australian business insurance
PI and Public Liability for Your Tours
Send us your tour descriptions and itinerary, and we will take them to the specialist markets that write tour operators and come back to you with the options available.