Credit licensees & mortgage brokers compliance obligations in Victoria: 20–99 employees
Computed by the Rules Mate applicability engine for a Pty Ltd company with 20–99 employees, turnover $3M–$10M, in credit licensees & mortgage brokers, operating in Victoria and selling to consumers and small businesses.
Short answer: 57 obligations
57 obligations apply (20 critical) across 27 regulators, plus 14 to check. Risk rating: high. Licensed or supervised regime: credit provider. These carry licence conditions, regulator audit and per-contravention civil penalties.
What changes at 20–99 employees
Compared with a credit licensees & mortgage brokers business with 6–19 employees in Victoria, 9 obligations apply that did not, and 1 drops away.
- Applies: Notifiable Data Breach (NDB) scheme
- Applies: Publish a Privacy Policy that meets APP 1
- Applies: Provide an APP 5 collection notice at or before collection
- Applies: APP 12 & APP 13 access and correction requests
- Applies: APP 7 direct marketing: consent, opt-out & when you can't message (2026)
- Applies: Pay redundancy under NES (s 119 FW Act)
- Applies: Privacy Act Reform — information controllers regime (proposed Tranche 2)
- Applies: Report ransomware and cyber extortion payments within 72 hours
- Applies: APP 2 — anonymity + pseudonymity for individuals
What switches on at 100–499 employees
Moving to a Pty Ltd company with 100–499 employees, turnover $10M–$100M adds 3 obligations:
Victoria law that applies
4 Victoria obligations apply on these facts, and 1 more is worth checking:
| Obligation | Why it applies |
|---|---|
| Notify VIC WorkSafe of notifiable WHS incidents | Every PCBU must notify the regulator of notifiable incidents (death, serious injury, dangerous incident) · VIC law |
| PCBU primary duty of care (Victoria OHS Act s 21) | Every business is a PCBU — the primary duty of care applies whether or not you employ anyone · VIC law |
| Comply with the General Environmental Duty (VIC) | The Victorian general environmental duty applies to every business activity that could cause harm from pollution or waste · VIC law |
| Pay long service leave under the LSL Act 2018 (Vic) | You have employees (20–99) · VIC law |
| Pay Victorian payroll tax when threshold met | Check: applies only if your annual Australian wages (grouped) exceed $1M |
Payroll tax in Victoria (FY2026-27)
VIC: 4.85% on Australian wages above the $1 million tax-free threshold (FY2026-27). On these facts it may apply: 20–99 employees in VIC — enter annual payroll to confirm; it applies only if your annual Australian wages (grouped) exceed $1M.
- How the threshold works
- Full threshold below $3M of Australian wages; between $3M and $5M it phases out at 50% of wages over $3M; no threshold above $5M.
- Surcharges
- Above $10M Australian wages: mental health and wellbeing surcharge 0.5% + COVID-19 debt surcharge 0.5%; above $100M a further 0.5% each (2% total).
- Regional concession
- 1.2125% regional employer rate
- Returns
- Monthly by the 7th of the following month; annual reconciliation by 21 July
- Administered by
- SRO Vic
Victoria regulators
Where the obligations sit
| Area | Obligations |
|---|---|
| Privacy | 9 |
| Workplace | 8 |
| Tax | 7 |
| Directors | 4 |
| Whs | 4 |
| Credit | 4 |
| Super | 2 |
| Migration | 2 |
| Corporations | 2 |
| Consumer law | 2 |
Critical obligations on this profile
- Notifiable Data Breach (NDB) scheme (Annual turnover over $3M — an APP entity under the Privacy Act (s 6D))
- Apply for a Director Identification Number (Director ID) (Incorporated company (Corporations Act))
- Comply with directors' general law and statutory duties (Incorporated company (Corporations Act))
- Prevent insolvent trading (s 588G) (Incorporated company (Corporations Act))
- Pay superannuation on every payday (Payday Super) (You have employees (20–99))
- Pay employees in accordance with the applicable modern award (You have employees (20–99))
- Manage psychosocial hazards at work (You have employees (20–99))
- Take reasonable and proportionate measures to prevent sex discrimination, sexual (You have employees (20–99))
Check whether these apply
- Mortgage broker best interests duty: only if you are a mortgage broker
- Comply with Design and Distribution Obligations (DDO): only if you issue or distribute retail financial or credit products
- Small Amount Credit Contract + Consumer Lease caps (post-SACC reforms): only if you provide small amount credit contracts or consumer leases
- Design and Distribution Obligations (DDO) — RG 274: only if you issue or distribute retail financial or credit products
- Lodge an FBT return and pay FBT by 21 May: only if you provide fringe benefits (cars, entertainment, loans) to employees
- Pay Victorian payroll tax when threshold met: only if your annual Australian wages (grouped) exceed $1M
- Wash outbound marketing lists against the Do Not Call Register: only if you make outbound telemarketing calls
- Influencer + ad disclosure under ACL + AANA Code: only if you advertise to consumers or engage influencers
Thresholds to watch
- WGEA gender pay gap reporting becomes mandatory (threshold 100 employees; very close)
Questions
- How many compliance obligations apply to credit licensees and mortgage brokers in Victoria with 20–99 employees?
- 57 obligations apply (20 critical) across 27 regulators, plus 14 to check. Risk rating: high. Licensed or supervised regime: credit provider. These carry licence conditions, regulator audit and per-contravention civil penalties.
- Which Victoria laws apply?
- Notify VIC WorkSafe of notifiable WHS incidents, PCBU primary duty of care (Victoria OHS Act s 21), Comply with the General Environmental Duty (VIC) and Pay long service leave under the LSL Act 2018 (Vic)
Related
- Credit licensees & mortgage brokers compliance in Victoria
- Credit licensees & mortgage brokers: all obligations
- Compliance obligations by industry, state and size
- Credit licensees & mortgage brokers in VIC: sole trader
- Credit licensees & mortgage brokers in VIC: sole trader with employees
- Credit licensees & mortgage brokers in VIC: partnership
- Credit licensees & mortgage brokers in VIC: trading trust
- Credit licensees & mortgage brokers in VIC: no employees
- Credit licensees & mortgage brokers in VIC: 1–5 employees
- Credit licensees & mortgage brokers in VIC: 100–499 employees
- Credit licensees & mortgage brokers in VIC: 20–99 employees, turnover $1M–$3M
- Credit licensees & mortgage brokers in VIC: 6–19 employees, turnover $3M–$10M
- Credit licensees & mortgage brokers in VIC: 100–499 employees, turnover $100M–$1B
- Credit licensees & mortgage brokers in VIC: 500+ employees, turnover $1B+
- Credit licensees & mortgage brokers in New South Wales: 20–99 employees
- Credit licensees & mortgage brokers in Queensland: 20–99 employees
- Credit licensees & mortgage brokers in Western Australia: 20–99 employees
- Credit licensees & mortgage brokers in South Australia: 20–99 employees
- Credit licensees & mortgage brokers in Tasmania: 20–99 employees
- Credit licensees & mortgage brokers in Northern Territory: 20–99 employees
- Credit licensees & mortgage brokers in Australian Capital Territory: 20–99 employees
- Comply with NCCP responsible lending obligations: does it apply to credit licensees & mortgage brokers?
- Mortgage broker best interests duty: does it apply to credit licensees & mortgage brokers?
- Comply with Design and Distribution Obligations (DDO): does it apply to credit licensees & mortgage brokers?
- Register security interests on the PPSR: does it apply to credit licensees & mortgage brokers?
Sources
- SRO Vic: payroll tax thresholds and rates
- Notify VIC WorkSafe of notifiable WHS incidents
- PCBU primary duty of care (Victoria OHS Act s 21)
- Comply with the General Environmental Duty (VIC)
- Pay long service leave under the LSL Act 2018 (Vic)
- Notifiable Data Breach (NDB) scheme
- Apply for a Director Identification Number (Director ID)
- Comply with directors' general law and statutory duties
Computed by the Rules Mate applicability engine from the published obligation corpus; facts last checked 3 October 2026. Rules Mate is not a law firm and this is general information, not legal advice. Confirm your position with the regulator source or a qualified adviser before acting.