Are BNPL products now regulated as credit?

Yes. As of 10 June 2025, BNPL products require a credit licence under Australian law. This means BNPL providers must comply with responsible lending obligations, including making reasonable inquiries about a consumer's financial situation before offering credit.

When will CDR expand to cover BNPL products?

CDR expansion to BNPL products is expected mid-2026. This will require BNPL providers to share product and customer data with accredited recipients, similar to existing banking CDR obligations.

How does banking data improve BNPL affordability checks?

CDR banking data provides real-time visibility into income, expenses, existing commitments, and cash flow patterns. This enables BNPL providers to assess whether a customer can genuinely afford additional credit obligations, going beyond credit scores alone.

What responsible lending obligations apply to BNPL?

BNPL providers must now make reasonable inquiries about a consumer's financial situation, verify information, and make a preliminary assessment that the credit is not unsuitable. This includes verifying income and assessing existing financial commitments.

How large is the Australian BNPL market?

The Australian BNPL market is projected to reach AUD $33.58 billion by 2029. With regulatory maturity comes opportunity — providers with strong affordability assessment capabilities will be better positioned to capture market share.

Can BNPL providers use CDR data for real-time transaction decisioning?

Yes. Fiskil's Banking API enables near-real-time access to banking data, supporting point-of-sale affordability checks. This allows BNPL providers to make informed decisions at the moment of transaction rather than relying on stale data.

How does BNPL regulation compare across Australia and New Zealand?

Australia introduced BNPL credit licence requirements on 10 June 2025. New Zealand introduced similar BNPL regulation under its Credit Contracts and Consumer Finance Act amendments. Both markets require responsible lending checks, creating demand for comprehensive affordability assessment tools.

Banking API for Buy Now Pay Later

Banking API for Buy Now Pay Later Providers

The Buy Now Pay Later industry entered a new regulatory era on 10 June 2025 when BNPL products came under credit licence requirements. With CDR expansion to BNPL expected mid-2026, providers now need robust affordability assessment capabilities and responsible lending compliance. Fiskil's Banking API enables BNPL providers to access real-time banking data for affordability checks, credit assessment, and responsible lending — turning regulatory requirements into competitive advantages.

The Challenge

BNPL providers face converging regulatory pressures: credit licence requirements since June 2025, upcoming CDR obligations mid-2026, and ASIC responsible lending scrutiny. Traditional affordability checks using limited data lead to over-commitment, defaults, and regulatory risk.

The Solution

Fiskil provides BNPL providers with real-time access to CDR banking data for comprehensive affordability assessment. Verify income, analyse expenses, detect existing commitments, and make responsible lending decisions — all through a single API integration.

Benefits

Key Benefits

Responsible Lending Compliance

Meet ASIC responsible lending obligations with bank-verified income and expense data for every affordability assessment.

Real-Time Affordability

Assess customer affordability at the point of sale using live bank data, not outdated credit bureau information.

Reduced Default Rates

Comprehensive income and expense visibility enables better lending decisions, reducing defaults and customer hardship.

CDR-Ready for Mid-2026

Prepare for CDR expansion to BNPL products with infrastructure that already meets CDR compliance requirements.

Use Cases

Common Use Cases

Affordability Checks

Real-time affordability assessment at the point of BNPL transaction.

Credit Assessment

Bank data-driven credit decisioning for BNPL applications.

Responsible Lending

Meeting ASIC responsible lending obligations for BNPL products.

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