BNPL providers — credit licensing from 10 June 2025
BNPL captured by the NCCP Act as a regulated credit product from 10 June 2025.
Who must comply
BNPL providers operating in Australia.
What triggers it
Providing BNPL services.
When due
ACL in place by 10 June 2025; ongoing compliance.
Evidence required
ACL, modified responsible lending procedures, hardship procedures, AFCA membership.
Max penalty
Civil penalties up to $16.5M / 3× benefit / 10% turnover; unlicensed conduct also criminal
Effective from
10 June 2025
Summary
The Treasury Laws Amendment (Responsible Buy Now Pay Later and Other Measures) Act 2024 brings Buy Now Pay Later within the NCCP Act as 'Low Cost Credit Contracts' from 10 June 2025. BNPL providers need an ACL and must apply modified responsible lending obligations.
Enforced by
Source legislation
Industries
Topics
Related obligations
- CWLTHComply with NCCP responsible lending obligationsCredit licensees must not enter into credit contracts unsuitable for the consumer.
- CWLTHMortgage broker best interests dutyBrokers must act in the consumer's best interests when providing credit assistance.
- CWLTHConsumer Credit Hardship Notice (NCC ss 72-73)Credit providers must respond to hardship notice + assess variation request.
- CWLTHSmall Amount Credit Contract + Consumer Lease caps (post-SACC reforms)SACC + consumer lease fee caps + responsible lending tightened post-Royal Commission.
- CWLTHRespond to hardship notices within statutory timeframeCredit providers must consider hardship notices within 21 days under s 72 NCC.
- CWLTHDisplay comparison rate on credit product advertisingAnnual percentage + comparison rate must accompany credit product ads under NCCP Regulations.
Frequently asked questions
- Who must comply with BNPL providers — credit licensing from 10 June 2025?
- BNPL providers operating in Australia.
- What triggers BNPL providers — credit licensing from 10 June 2025?
- Providing BNPL services.
- When is BNPL providers — credit licensing from 10 June 2025 due?
- ACL in place by 10 June 2025; ongoing compliance.
- What is the maximum penalty for BNPL providers — credit licensing from 10 June 2025?
- Civil penalties up to $16.5M / 3× benefit / 10% turnover; unlicensed conduct also criminal
- What evidence is required for BNPL providers — credit licensing from 10 June 2025?
- ACL, modified responsible lending procedures, hardship procedures, AFCA membership.
Source: https://treasury.gov.au/consultation/c2023-431524. Rules Mate is not a law firm. Always verify against the live regulator source before acting.