Meeting ASIC Responsible Lending Obligations for BNPL

Reasonable Inquiries Automation

CDR bank data provides evidence of genuine inquiry into the consumer's financial situation — income, expenses, commitments, and financial behaviour — satisfying ASIC's reasonable inquiries standard without manual investigation.

Not Unsuitable Assessment

Automatically assess whether the proposed BNPL credit is "not unsuitable" by verifying the consumer can meet repayments without substantial hardship, using real expense and commitment data.

Hardship Indicator Detection

Proactively identify consumers showing signs of financial hardship — overdrawn accounts, dishonoured payments, reliance on high-cost credit — before extending additional BNPL credit.

Compliance Documentation

Automatically generate and store responsible lending assessment records for every transaction, creating a defensible audit trail for ASIC review.

Integrate Fiskil's API and implement CDR consent collection during customer onboarding. This provides the ongoing data access needed for continuous responsible lending assessment.

Define your responsible lending assessment rules — income thresholds, expense buffers, hardship indicators, and escalation triggers — in consultation with your compliance team.

For each BNPL transaction, Fiskil evaluates the consumer's current financial position against your configured rules and returns a compliant assessment decision with supporting evidence.

Every assessment generates a structured compliance record capturing the data reviewed, rules applied, and decision reached — available for internal audit, ASIC requests, or EDR complaints.