Banking API — BNPL
Meeting ASIC Responsible Lending Obligations for BNPL
Satisfy ASIC's "reasonable inquiries" and "not unsuitable" assessment requirements for the AUD $33.58B BNPL market. Fiskil provides the CDR data infrastructure for compliant responsible lending at BNPL scale.
The Australian BNPL market is valued at AUD $33.58 billion, and since 10 June 2025, every BNPL transaction must satisfy responsible lending obligations under the National Consumer Credit Protection Act. ASIC requires providers to make "reasonable inquiries" about a consumer's financial situation and assess that credit is "not unsuitable" — meaning the consumer can meet repayments without substantial hardship. Fiskil provides the CDR data layer that enables BNPL providers to meet these obligations at transaction speed and scale.
The Challenge
BNPL providers must apply responsible lending standards designed for traditional credit to millions of small, fast transactions without destroying the business model.
The Solution
Fiskil enables BNPL providers to satisfy both the "reasonable inquiries" and "not unsuitable" limbs of the responsible lending test using CDR bank data, at a speed and cost compatible with BNPL economics.
Capabilities
How Fiskil Helps
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.
Implementation
How It Works
Establish CDR Data Foundation
Integrate Fiskil's API and implement CDR consent collection during customer onboarding. This provides the ongoing data access needed for continuous responsible lending assessment.
Configure Assessment Framework
Define your responsible lending assessment rules — income thresholds, expense buffers, hardship indicators, and escalation triggers — in consultation with your compliance team.
Automate Per-Transaction Assessment
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.
Maintain Audit Trail
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.
In Practice
How Teams Use This
Tier-1 BNPL Provider Licence Transition
A major BNPL provider transitioning to a credit licence regime needed to implement responsible lending across 3.2 million active customers and 8 million monthly transactions.
Full responsible lending compliance achieved within 4 months of the 10 June 2025 deadline. ASIC acknowledged the implementation as meeting expected standards during supervisory engagement.
Reducing Hardship Claims
A mid-tier BNPL provider experiencing growing hardship claims from consumer advocates implemented CDR-based hardship detection to prevent lending to consumers in financial difficulty.
Hardship claims reduced by 47% within 6 months. Customer complaints to the Australian Financial Complaints Authority dropped by 38%.
Embedded BNPL Compliance
A fintech offering white-label embedded BNPL to retailers needed a scalable responsible lending solution that could be deployed across hundreds of merchant integrations.
Single CDR integration powered responsible lending compliance across 340 merchant partners. Per-transaction compliance cost reduced to AUD $0.12, making responsible lending economically viable for transactions as small as AUD $50.
Technical Details
What You Integrate With
API endpoints
GET /v1/accountsGET /v1/accounts/{accountId}/transactionsPOST /v1/affordability/assessPOST /v1/responsible-lending/evaluate
Data returned
Reasonable inquiries evidence
Not unsuitable assessment
Hardship indicators
Compliance audit record
Consumer outcome metrics
Authorisation
OAuth 2.0 / CDR consent
Real-time data access.
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FAQs
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