New BNPL Regulations: Now in Effect
With ASIC's implementation of Regulatory Guide 281 following the May 8 announcement, the buy now pay later (BNPL) industry is now operating under significant regulatory changes that commenced June 10, 2025.
These changes, stemming from the Treasury Laws Amendment (Responsible Buy Now Pay Later and Other Measures) Act 2024, now require BNPL providers to hold credit licenses and comply with various obligations, including monitoring requirements and responsible lending assessments.
Licensed BNPL providers now need robust product governance solutions to maintain ongoing compliance. This is where Skyjed's product lifecycle management platform offers substantial value.
How Skyjed Supports BNPL Regulatory Compliance
Unsuitability Assessment Policy Monitoring
The current regulations require BNPL providers to maintain and regularly review an "unsuitability assessment policy." Skyjed's product-level monitoring capabilities provide a systematic approach to this requirement by:
- Enabling scheduled policy reviews with automated reminders.
- Tracking aggregated performance metrics across your product portfolio, including delinquency rates, approval/rejection ratios, and write-off rates.
- Providing trend analysis to identify emerging patterns at the product level before they become compliance issues.
- Documenting review outcomes and policy adjustments with comprehensive audit trails.
Target Market Determination Integration
Since the current regulations reference target market determinations (TMDs) as a factor in assessing what constitutes "reasonable" enquiries, Skyjed's TMD management features are particularly valuable including:
- Linking TMD reviews with BNPL assessment requirements
- Simplifying the creation and maintenance of TMDs for different BNPL products
- Providing data-driven insights on whether product performance aligns with target market specifications
- Facilitating the monitoring of aggregated product performance against TMD parameters
Fee Cap Monitoring and Management
Skyjed helps providers manage the critical fee cap requirements at the product level with:
- Aggregated analytics showing the distribution of customers approaching fee cap thresholds
- Trend monitoring to identify products with increasing fee cap utilisation
- Risk assessment frameworks to proactively identify potential compliance issues
- Comprehensive reporting for regulatory oversight and internal governance
Responsible Lending Documentation
Our platform streamlines the monitoring of responsible lending practices at the product level including:
- Assessment criteria configuration and version control
- Aggregated metrics on approval rates, decline reasons, and compliance indicators
- Performance tracking of assessment frameworks by credit amount thresholds
Credit Limit Increase Management
For providers utilising the "protected increase" provisions, Skyjed offers product-level insights:
- Configuration frameworks for protected increase policies
- Aggregated performance metrics on credit limit increases
- Trend analysis of post-increase account performance
- Compliance monitoring of protected increase implementation
Election and Revocation Management
Skyjed provides robust support for managing elections to comply with modified responsible lending obligations:
- Election configuration and documentation at the product level
- Coverage analytics showing which products and contract volumes are under elections
- Documentation compliance monitoring
- Regulatory retention management
Complaint and Hardship Monitoring
To support the requirement for handling complaints and hardship applications:
- Product-level complaint analytics by category and resolution metrics
- Hardship application trends and outcome analysis
- Comparative performance between pre-commencement and current contracts
- Identification of systemic issues requiring policy adjustments
Beyond Compliance: Building Sustainable Product Governance
While meeting the ongoing regulatory requirements is critical, forward-thinking BNPL providers recognise that effective product governance delivers business benefits beyond compliance. Skyjed's platform helps transform regulatory requirements into operational advantages by:
- Improving product performance through aggregated data insights
- Reducing remediation costs through early detection of product-level issues
- Enhancing customer experiences through better product design
- Building trust with consumers and regulators through transparent governance
As ASIC Commissioner Alan Kirkland noted, these reforms represent "an important step to improve protection for Australian consumers who use buy now pay later products." With Skyjed as your product governance partner, you can not only meet these ongoing requirements but transform them into an opportunity to strengthen your market position through superior product lifecycle management.
Ready to transform your compliance approach?
Contact Skyjed today for a personalised demonstration.
About Skyjed
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Skyjed’s AI-powered end-to-end lifecycle and governance platform is mission control for lifecycle management and governance. Bringing together every data point across your portfolio and lifecycle into a single source of truth, it gives our clients a new perspective to make more strategic lifecycle decisions to launch, monitor, optimise, and win.
Our industry-leading platform has received numerous awards and recognition from clients and industry bodies, demonstrating our commitment to innovation and excellence.
