Industry Requirements from 10th June 2025
Key Industry Requirements | Payright’s position |
| All BNPL service providers will be required to hold an Australian Credit Licence (ACL) to operate. | Navalo Financial Services Group Limited (trading as Payright) holds Australian Credit Licence number 533485. |
| BNPL providers must be members of the Australian Financial Complaints Authority (AFCA) | Payright is an existing member of AFCA and is committed to ensuring customers can access prompt, efficient and courteous complaints management. |
| Responsible Lending Obligations BNPL providers will be subject to new scalable obligations related to responsible lending. | Payright must assess whether the BNPL product is not unsuitable for the customer. This will involve inquiring into a customer’s requirements and objectives, financial situation and taking reasonable steps to verify their financial situation. Payright is scaling how it conducts its lending assessments based on loan size and customer risk profile and are currently building this into our bespoke decisioning platform to ensure we continue Payright’s reputation for simplicity & ease. |
| BNPL providers will need to comply with the general conduct obligations of credit providers under the Credit Act, including pre-contractual disclosure requirements | The Credit Act requires Payright to provide financial disclosures to customers before they sign up to a BNPL product. Payright already fulfils these requirements in relation to its PayrightPlus personal loan product, so Payright is well positioned to design and implement these requirements in a way that prioritises the customer experience. All new disclosures will be delivered to customers electronically within a seamless online application flow. |
| Fee Caps: There will be caps on the credit fees and charges that BNPL providers can charge customers. New fee caps apply to default fees. | Payright’s BNPL Product already has caps on credit fees and default fees. Payright will ensure that these fee caps remain compliant going forward. |
| Focus on Financial Vulnerability | Payright is committed to looking after all its customers, including any customers experiencing a temporary or permanent vulnerability and will continue to honour this commitment under the new laws. This includes considering whether a person is experiencing financial vulnerability during the application process and working with customers in a vulnerable position. We offer hardship support where needed and encourage these customers to contact our team should they be experiencing any difficulty in meeting their obligations to us. |