Do credit licensees and mortgage brokers need to comply with Design and Distribution Obligations (DDO)?
A computed answer from the Rules Mate applicability engine, with the exact condition, the outcome for every structure and size, and the primary source.
Short answer: Only if
Only if you issue or distribute retail financial or credit products. Being in this industry makes the obligation worth checking (Credit licensee industry), but the trigger is a fact the industry alone does not settle.
The obligation in brief
Comply with Design and Distribution Obligations (DDO). 8A of the Corporations Act requires issuers and distributors of retail financial products (including credit) to make a target market determination (TMD), distribute consistently with the TMD, report significant dealings inconsistent with it, and review TMDs periodically.
Trigger: Issuing or distributing in-scope products.
Why credit licensees & mortgage brokers get a different answer
Rules Mate runs its applicability engine across 9 business structures and 6 size bands for each of the 35 industries it maps. For 31 of those industries the answer for "Comply with Design and Distribution Obligations (DDO)" is no. Credit licensees & mortgage brokers is one of the 4 where the answer is different: only if.
The deciding fact for credit licensees and mortgage brokers: Credit licensee industry; applies only if you issue or distribute retail financial or credit products.
About the industry: ACL holders and mortgage brokers under the NCCP Act.
Compare a professional services (general) business with 6–19 employees structured as a Pty Ltd company: the obligation does not apply (Requires issues products or an ACL or APRA regulation).
Answer by business structure and size
Each cell is the engine's outcome for a business in credit licensees & mortgage brokers with that structure and size, assuming it sells to consumers and small businesses and holds customer contact details. "Check" means the obligation turns on a fact the industry does not settle.
| Structure | No employees | 1–5 employees | 6–19 employees | 20–99 employees | 100–499 employees | 500+ employees |
|---|---|---|---|---|---|---|
| Sole trader | Check | Check | Check | Check | Check | Check |
| Partnership | Check | Check | Check | Check | Check | Check |
| Trust | Check | Check | Check | Check | Check | Check |
| Pty Ltd company | Check | Check | Check | Check | Check | Check |
| Public company | Check | Check | Check | Check | Check | Check |
| Not-for-profit (unregistered) | Check | Check | Check | Check | Check | Check |
| Registered charity | Check | Check | Check | Check | Check | Check |
| Super fund | Check | Check | Check | Check | Check | Check |
| Foreign company | Check | Check | Check | Check | Check | Check |
What the obligation requires
- When due
- Continuous; TMDs reviewed periodically and on trigger events.
- Evidence to keep
- Documented TMD, distribution monitoring data, significant-dealings register, TMD review records.
- Maximum penalty
- Civil penalties to the maximum financial-services regime ($18.2M / 3× benefit / 10% turnover)
- Regulator
- ASIC
- Jurisdiction
- Commonwealth (national)
Other obligations where credit licensees & mortgage brokers differ from the norm
- Design and Distribution Obligations (DDO) — RG 274: Only if
- Comply with NCCP responsible lending obligations: Yes
- Consumer Credit Hardship Notice (NCC ss 72-73): Yes
- Mortgage broker best interests duty: Only if
- Register security interests on the PPSR: Yes
- Small Amount Credit Contract + Consumer Lease caps (post-SACC reforms): Only if
- All 11 answers for credit licensees & mortgage brokers
Other industries with a non-default answer
Questions
- Do credit licensees and mortgage brokers need to comply with Design and Distribution Obligations (DDO)?
- Only if you issue or distribute retail financial or credit products. Being in this industry makes the obligation worth checking (Credit licensee industry), but the trigger is a fact the industry alone does not settle.
- Is the answer the same for every industry?
- No. For 31 of the 35 industries Rules Mate maps, the answer is no. Credit licensees & mortgage brokers is one of 4 industries with a different answer.
Related
Sources
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.