---
title: "BNPL Is Credit Now: What the Licence Means in Practice | Astris Law"
url: https://www.astrislaw.com/article/bnpl-credit-licence-in-practice
description: "Buy now pay later entered Australia's national consumer credit regime in June 2025. What the credit licence and modified responsible lending framework change for providers, partners and products built near the boundary."
lang: en-AU
---

Skip to main content

← Back to Articles: https://www.astrislaw.com/articles
|
Regulatory & Compliance →: https://www.astrislaw.com/practice/regulatory-compliance-consumer-law

Insights 7 August 2026 • 6 min read

# BNPL Is Credit Now: What the Licence Means in Practice

## Summary

From June 2025 buy now pay later sits inside the national consumer credit regime, with providers required to hold an Australian credit licence and apply a modified responsible lending framework. The licence is the visible change. What it does to product design, funding and partnerships is the real one.

Last reviewed 7 August 2026 · Reviewed by Jamie Nuich (https://www.astrislaw.com/attorney/jamie-nuich), Legal Practitioner Director

## Key Takeaways

- Buy now pay later was brought inside the national consumer credit regime from June 2025, with providers required to hold an Australian credit licence.
- Providers must apply a modified responsible lending framework, and what modified means for a specific product is a design question rather than a checkbox.
- The perimeter is technology neutral and turns on substance and rights, so products built near BNPL cannot rely on labels to stay outside it.
- The licence reshapes funding, partnerships and product design, not just compliance, and the order those are resolved in decides the cost.
- BNPL is one chapter in a wider widening of the licensing perimeter, with payments licensing reform underway and the digital assets regime commencing in 2027.

Image: Payment card and banking imagery illustrating buy now pay later products entering the consumer credit regime (https://www.astrislaw.com/images/articles/banking.jpg)

In This Article

1. 1. In Brief
2. 2. What Actually Changed
3. 3. Modified Does Not Mean Light
4. 4. The Ripple Effects Nobody Priced
5. 5. One Chapter, Not the Whole Story
6. 6. Frequently Asked Questions

For years buy now pay later was the standing exception in Australian consumer finance: credit shaped products that lived outside the credit regime. That ended in June 2025, when BNPL was brought inside the national consumer credit regime, with providers required to hold an Australian credit licence and apply a modified responsible lending framework. The licence is the change everyone can see. What the licence does to the business behind it is the change that decides who is still standing in five years.

## In Brief

- From June 2025 buy now pay later sits inside the national consumer credit regime.
- Providers are required to hold an Australian credit licence and apply a modified responsible lending framework.
- The perimeter turns on substance and rights, not labels, so adjacent products are not automatically safe.
- The licence reshapes product design, funding and partnerships, not just the compliance function.
- This is one chapter in a wider widening of the perimeter, with payments licensing reform underway.

## What Actually Changed

Before June 2025 the BNPL sector's structural advantage was regulatory. The product delivered something that behaved like credit to the customer without carrying the licensing and responsible lending load of credit for the provider. Bringing BNPL inside the national consumer credit regime removed that asymmetry. A provider now needs an Australian credit licence, and with the licence comes an obligations framework that reaches into how the product is designed, offered and monitored.

It is worth being precise about what that means. A licence is not a certificate on the wall. It is an ongoing set of obligations attached to an ongoing relationship with a regulator, and it changes who is allowed to be in the room when decisions about the product get made. Businesses that treated the licence as a filing exercise are discovering that the filing was the easy part.

## Modified Does Not Mean Light

The framework BNPL providers must apply is a modified responsible lending framework. The word modified has done a lot of comforting work in boardrooms, and some of that comfort is misplaced. Modified means the framework has been adapted to the product class. It does not mean the framework is optional, and it does not mean the answers for your specific product are obvious. What the modified settings require of your onboarding, your assessment approach and your product terms is a design question that depends on what your product actually is and how it is actually used.

That design question is where the commercial stakes live. Two providers can hold the same licence and apply the same framework and end up with very different conversion rates, cost structures and regulatory postures, because one designed the product and the obligations together and the other bolted compliance onto a finished product. The second approach is always more expensive. It is just expensive later.

## The Ripple Effects Nobody Priced

The licence changes more than the provider's own obligations. It changes the questions everyone around the provider asks. Funders and warehouse providers now diligence the licence position and the responsible lending approach, because a regulatory failure in the book is a problem for the capital behind it. Merchant partners and platforms that distribute BNPL now sit closer to a regulated product than they did, and the arrangements that govern that distribution deserve more attention than a standard referral agreement gives them. Acquirers price licence and compliance posture into every transaction in the sector.

And then there is the boundary population: the instalment products, the pay later features and the credit adjacent tools that were built to sit near BNPL without being BNPL. Whether something is a credit product turns on substance and rights, not labels, and the licensing perimeter under the National Consumer Credit Protection Act 2009 (Cth) is technology neutral. If your product's regulatory position is a label, June 2025 is the reason to have the position tested properly.

## One Chapter, Not the Whole Story

BNPL did not move inside the perimeter because of anything unique to BNPL. It moved because the perimeter follows substance, and eventually the gap between what a product is and how it is regulated closes. The same movement is visible elsewhere. A reform of payments system licensing, a licensing framework for payment service providers, is in progress in Australia. The Corporations Amendment (Digital Assets Framework) Act 2026 (Cth) commences on 9 April 2027 and brings digital asset platforms into the AFSL regime. Different sectors, same direction.

For operators the lesson is sequencing. The providers who mapped their position before the BNPL reforms landed chose their pathway. The ones who waited had a pathway chosen for them, on a timeline they did not control. The next cohorts, in payments and digital assets, are being sorted into those two groups right now.

## Frequently Asked Questions

### Does every BNPL provider need an Australian credit licence?

From June 2025 buy now pay later sits inside the national consumer credit regime and providers are required to hold an Australian credit licence. Whether a specific product is caught turns on the substance of the arrangement, which is exactly why the analysis should be done on your actual product rather than on its category name.

### What is the modified responsible lending framework?

It is the adapted responsible lending settings that BNPL providers must apply under the reforms. What it requires of a specific product is a design question that depends on the product and the arrangement, and it is worth resolving with advice rather than by analogy to a competitor.

### My product is instalments but not marketed as BNPL. Am I affected?

Possibly. The perimeter turns on substance and rights, not labels, and it is technology neutral. A product that behaves like credit can be treated as credit whatever it is called. The position is worth testing before someone else tests it.

### We distribute BNPL as a merchant or platform. Does any of this reach us?

The reforms changed the regulatory character of the product you distribute, and that changes what your distribution arrangements should deal with. The exposure depends on the arrangement, which is a reviewable document rather than a mystery.

If your product sits in or near the credit perimeter, the cheapest time to know is now. Read more on our payments licensing page (https://www.astrislaw.com/payments-licensing-lawyer), Contact Astris Law (https://www.astrislaw.com/consultation) for a fixed fee consultation or call (07) 3519 5616 (+61735195616).

## Sources and References

- Legislation National Consumer Credit Protection Act 2009 (Cth)
- Legislation Corporations Act 2001 (Cth)

Share Share on LinkedIn (https://www.linkedin.com/sharing/share-offsite/?url=https%3A%2F%2Fwww.astrislaw.com%2Farticle%2Fbnpl-credit-licence-in-practice)Share on X (https://twitter.com/intent/tweet?url=https%3A%2F%2Fwww.astrislaw.com%2Farticle%2Fbnpl-credit-licence-in-practice&text=BNPL%20Is%20Credit%20Now%3A%20What%20the%20Licence%20Means%20in%20Practice)Share on Facebook (https://www.facebook.com/sharer/sharer.php?u=https%3A%2F%2Fwww.astrislaw.com%2Farticle%2Fbnpl-credit-licence-in-practice)

This article is for general information purposes only and does not constitute legal advice and should not be relied on as such. While we take reasonable care to ensure the accuracy of the information provided, we make no representations or warranties as to its completeness, currency or reliability. We accept no liability for any loss or damage arising directly or indirectly from the use of, or reliance on, this website's content. You should always seek professional advice tailored to your specific circumstances before acting on any information in this article. Liability limited by a scheme approved under Professional Standards Legislation.

Related Practice Area

Regulatory & Compliance
https://www.astrislaw.com/practice/regulatory-compliance-consumer-law

## Running or building a BNPL or credit adjacent product?

Whether your product is caught, what the licence means for its design and how to sequence the pathway are questions best answered before a regulator or a partner asks them. Astris Law offers a fixed fee consultation protected by legal professional privilege. Book a call back on (07) 3519 5616.

(07) 3519 5616: +61735195616
Send an enquiry: https://www.astrislaw.com/contact

## Related Articles

Insights

### 38 Compliance Actions in June: What the NDIS Commission's Enforcement Numbers Mean for Providers

Read more
https://www.astrislaw.com/article/ndis-commission-38-compliance-actions-june-2026

Insights

### The 1 October SIL Registration Deadline: Which Scenario Are You In?

Read more
https://www.astrislaw.com/article/sil-mandatory-registration-1-october-2026

Insights

### Could an AI Law Firm Launch in Australia? The Garfield Question

Read more
https://www.astrislaw.com/article/ai-law-firm-australia-garfield-question

Book a call back (+61735195616)

## Structured data

```json
[
  {
    "@context": "https://schema.org",
    "@type": [
      "LegalService",
      "LocalBusiness"
    ],
    "@id": "https://www.astrislaw.com/#organization",
    "name": "Astris Law",
    "legalName": "Astris Law Pty Ltd",
    "alternateName": [
      "Astrons General Counsel",
      "Phronesis Litigation",
      "HeadStart Counsel"
    ],
    "url": "https://www.astrislaw.com",
    "logo": {
      "@type": "ImageObject",
      "url": "https://www.astrislaw.com/android-chrome-512x512.png",
      "width": 512,
      "height": 512
    },
    "image": "https://www.astrislaw.com/android-chrome-512x512.png",
    "description": "The Astris Law group gives directors and business owners the right legal capability for whatever their business needs, across corporate, disputes and regulatory. Not more lawyers than you need, the right one for the matter. Astris Law for one senior lawyer on high-stakes work, Astrons General Counsel for an embedded legal function, Phronesis Litigation for litigation intelligence, HeadStart Counsel for AML and CTF. One group, one standard, the right fit for each need.",
    "foundingDate": "2023",
    "founder": {
      "@type": "Person",
      "@id": "https://www.astrislaw.com/attorney/jamie-nuich#person",
      "name": "Jamie Nuich",
      "jobTitle": "Legal Practitioner Director",
      "url": "https://www.astrislaw.com/attorney/jamie-nuich"
    },
    "telephone": "+61735195616",
    "email": "mail@astrislaw.com",
    "contactPoint": [
      {
        "@type": "ContactPoint",
        "telephone": "+61735195616",
        "contactType": "customer service",
        "areaServed": "AU",
        "availableLanguage": "English",
        "hoursAvailable": "Mo-Fr 09:00-17:00"
      },
      {
        "@type": "ContactPoint",
        "telephone": "+61735195616",
        "contactType": "reservations",
        "name": "New matter intake",
        "areaServed": "AU",
        "availableLanguage": "English"
      }
    ],
    "aggregateRating": {
      "@type": "AggregateRating",
      "ratingValue": "5.0",
      "reviewCount": 12,
      "bestRating": "5",
      "worstRating": "1"
    },
    "review": [
      {
        "@type": "Review",
        "author": {
          "@type": "Person",
          "name": "Katherine, Director"
        },
        "reviewBody": "Jamie is someone any entrepreneur looking to change the game needs on their side.",
        "reviewRating": {
          "@type": "Rating",
          "ratingValue": "5",
          "bestRating": "5",
          "worstRating": "1"
        }
      },
      {
        "@type": "Review",
        "author": {
          "@type": "Person",
          "name": "Tracy, COO"
        },
        "reviewBody": "Jamie was approachable, took the time to really understand our business, communicated well ...",
        "reviewRating": {
          "@type": "Rating",
          "ratingValue": "5",
          "bestRating": "5",
          "worstRating": "1"
        }
      },
      {
        "@type": "Review",
        "author": {
          "@type": "Person",
          "name": "Matthew, Director"
        },
        "reviewBody": "... very educated in her field of law ...",
        "reviewRating": {
          "@type": "Rating",
          "ratingValue": "5",
          "bestRating": "5",
          "worstRating": "1"
        }
      },
      {
        "@type": "Review",
        "author": {
          "@type": "Person",
          "name": "Jenny, Investor"
        },
        "reviewBody": "For anyone needing a sharp, reliable lawyer, I can't recommend Jamie enough.",
        "reviewRating": {
          "@type": "Rating",
          "ratingValue": "5",
          "bestRating": "5",
          "worstRating": "1"
        }
      }
    ],
    "priceRange": "$$$",
    "address": {
      "@type": "PostalAddress",
      "streetAddress": "Level 2, 8 Clunies Ross Court",
      "addressLocality": "Eight Mile Plains",
      "addressRegion": "QLD",
      "postalCode": "4113",
      "addressCountry": "AU"
    },
    "geo": {
      "@type": "GeoCoordinates",
      "latitude": -27.5783,
      "longitude": 153.0996
    },
    "hasMap": "https://maps.app.goo.gl/KcW4jYe7iW7jHYHp8",
    "areaServed": [
      {
        "@type": "City",
        "name": "Brisbane"
      },
      {
        "@type": "City",
        "name": "Gold Coast"
      },
      {
        "@type": "State",
        "name": "Queensland"
      },
      {
        "@type": "Country",
        "name": "Australia"
      }
    ],
    "openingHoursSpecification": {
      "@type": "OpeningHoursSpecification",
      "dayOfWeek": [
        "Monday",
        "Tuesday",
        "Wednesday",
        "Thursday",
        "Friday"
      ],
      "opens": "08:30",
      "closes": "17:30"
    },
    "knowsAbout": [
      "Dispute Resolution & Litigation",
      "Insolvency & Restructuring",
      "Corporate & Commercial",
      "Employment & Workplace Relations",
      "Regulatory & Compliance",
      "Intellectual Property, Technology & Data",
      "Property",
      "Disciplinary Law",
      "Administrative Law & WHS",
      "Anti-Money Laundering (AML/CTF)",
      "Corporate Law",
      "Commercial Litigation",
      "Regulatory Compliance",
      "Financial Services Law",
      "Anti-Money Laundering",
      "FinTech Law",
      "Intellectual Property"
    ],
    "hasOfferCatalog": {
      "@type": "OfferCatalog",
      "name": "Legal services",
      "itemListElement": [
        {
          "@type": "Offer",
          "itemOffered": {
            "@type": "Service",
            "name": "Dispute Resolution & Litigation",
            "description": "Strategic commercial litigation, debt recovery, injunctions and alternative dispute resolution for directors and business owners across Australia.",
            "url": "https://www.astrislaw.com/practice/dispute-resolution-litigation",
            "provider": {
              "@id": "https://www.astrislaw.com/#organization"
            }
          }
        },
        {
          "@type": "Offer",
          "itemOffered": {
            "@type": "Service",
            "name": "Corporate & Commercial",
            "description": "Corporate and commercial advice for directors and business owners: company structuring, M&A, shareholder agreements, commercial contracts and director duties.",
            "url": "https://www.astrislaw.com/commercial-lawyers-brisbane",
            "provider": {
              "@id": "https://www.astrislaw.com/#organization"
            }
          }
        },
        {
          "@type": "Offer",
          "itemOffered": {
            "@type": "Service",
            "name": "Employment & Workplace",
            "description": "Practical advice on Fair Work compliance, unfair dismissal, restraints of trade and workplace disputes for directors and business owners.",
            "url": "https://www.astrislaw.com/practice/employment-workplace-relations",
            "provider": {
              "@id": "https://www.astrislaw.com/#organization"
            }
          }
        },
        {
          "@type": "Offer",
          "itemOffered": {
            "@type": "Service",
            "name": "Regulatory & Compliance",
            "description": "Defending and advising on ASIC, ACCC, AUSTRAC, NDIS Commission, AHPRA and WorkCover investigations, AML/CTF programs and Australian Consumer Law compliance for regulated businesses and professionals.",
            "url": "https://www.astrislaw.com/practice/regulatory-compliance-consumer-law",
            "provider": {
              "@id": "https://www.astrislaw.com/#organization"
            }
          }
        }
      ]
    },
    "member": [
      {
        "@type": "Person",
        "@id": "https://www.astrislaw.com/attorney/jamie-nuich#person",
        "name": "Jamie Nuich",
        "jobTitle": "Legal Practitioner Director",
        "url": "https://www.astrislaw.com/attorney/jamie-nuich",
        "image": "https://www.astrislaw.com/images/jamie-nuich-portrait.jpg",
        "hasCredential": [
          {
            "@type": "EducationalOccupationalCredential",
            "credentialCategory": "degree",
            "name": "Bachelor of Laws (Honours)"
          },
          {
            "@type": "EducationalOccupationalCredential",
            "credentialCategory": "degree",
            "name": "Bachelor of Business (Distinction)"
          },
          {
            "@type": "EducationalOccupationalCredential",
            "credentialCategory": "professional",
            "name": "Solicitor of the Supreme Court of Queensland"
          },
          {
            "@type": "EducationalOccupationalCredential",
            "credentialCategory": "professional",
            "name": "Solicitor of the High Court of Australia"
          },
          {
            "@type": "EducationalOccupationalCredential",
            "credentialCategory": "certification",
            "name": "Nationally Accredited Mediator (NMAS)"
          }
        ],
        "memberOf": [
          {
            "@type": "Organization",
            "name": "Queensland Law Society"
          },
          {
            "@type": "Organization",
            "name": "Australian Disputes Centre"
          }
        ],
        "sameAs": [
          "https://www.linkedin.com/in/jamienuich/",
          "https://www.qls.com.au/register-of-solicitors/jamie-leanne-nuich",
          "https://www.youandthelaw.com.au/organisation/98611/astris-law-pty-ltd"
        ]
      }
    ],
    "sameAs": [
      "https://astrons.astrislaw.com",
      "https://phronesis.astrislaw.com",
      "https://headstartcounsel.astrislaw.com",
      "https://www.linkedin.com/company/astris-law",
      "https://www.youandthelaw.com.au/organisation/98611/astris-law-pty-ltd",
      "https://maps.app.goo.gl/KcW4jYe7iW7jHYHp8",
      "https://lawzana.com/lawyer/astris-law",
      "https://www.gpmg.uk/awarded-companies/astris-law",
      "https://www.qls.com.au/register-of-solicitors/jamie-leanne-nuich",
      "https://www.linkedin.com/in/jamienuich/"
    ],
    "slogan": "You don't need more lawyers. You need the right one.",
    "subOrganization": [
      {
        "@type": "LegalService",
        "@id": "https://astrons.astrislaw.com/#organization",
        "name": "Astrons General Counsel",
        "url": "https://astrons.astrislaw.com",
        "description": "External general counsel for established Australian businesses: embedded, partner-level legal support combining law firm depth with in-house continuity.",
        "parentOrganization": {
          "@id": "https://www.astrislaw.com/#organization"
        }
      },
      {
        "@type": "LegalService",
        "name": "HeadStart Counsel",
        "url": "https://headstartcounsel.astrislaw.com",
        "description": "AML/CTF Tranche 2 compliance counsel for Australian professional services businesses.",
        "parentOrganization": {
          "@id": "https://www.astrislaw.com/#organization"
        }
      },
      {
        "@type": "Organization",
        "@id": "https://phronesis.astrislaw.com/#organization",
        "name": "Phronesis Litigation",
        "url": "https://phronesis.astrislaw.com",
        "description": "Astris Law's in-house litigation intelligence engine: legal research at machine speed, strategy earlier and disputes run with fewer surprises.",
        "parentOrganization": {
          "@id": "https://www.astrislaw.com/#organization"
        }
      }
    ],
    "brand": [
      {
        "@type": "Brand",
        "name": "Astrons General Counsel",
        "url": "https://astrons.astrislaw.com"
      },
      {
        "@type": "Brand",
        "name": "Phronesis Litigation",
        "url": "https://phronesis.astrislaw.com"
      },
      {
        "@type": "Brand",
        "name": "HeadStart Counsel",
        "url": "https://headstartcounsel.astrislaw.com"
      }
    ]
  },
  {
    "@context": "https://schema.org",
    "@type": "WebSite",
    "@id": "https://www.astrislaw.com/#website",
    "name": "Astris Law",
    "url": "https://www.astrislaw.com",
    "publisher": {
      "@id": "https://www.astrislaw.com/#organization"
    },
    "inLanguage": "en-AU",
    "potentialAction": {
      "@type": "SearchAction",
      "target": {
        "@type": "EntryPoint",
        "urlTemplate": "https://www.astrislaw.com/articles?q={search_term_string}"
      },
      "query-input": "required name=search_term_string"
    }
  },
  {
    "@context": "https://schema.org",
    "@type": "SiteNavigationElement",
    "@id": "https://www.astrislaw.com/#navigation",
    "name": "Main Navigation",
    "hasPart": [
      {
        "@type": "WebPage",
        "name": "About",
        "url": "https://www.astrislaw.com/about"
      },
      {
        "@type": "WebPage",
        "name": "The Group",
        "url": "https://www.astrislaw.com/philosophy"
      },
      {
        "@type": "WebPage",
        "name": "Practice Areas",
        "url": "https://www.astrislaw.com/practice-areas"
      },
      {
        "@type": "WebPage",
        "name": "Articles",
        "url": "https://www.astrislaw.com/articles"
      },
      {
        "@type": "WebPage",
        "name": "Contact",
        "url": "https://www.astrislaw.com/contact"
      }
    ]
  },
  {
    "@context": "https://schema.org",
    "@graph": [
      {
        "@type": "WebPage",
        "@id": "https://www.astrislaw.com/article/bnpl-credit-licence-in-practice#webpage",
        "url": "https://www.astrislaw.com/article/bnpl-credit-licence-in-practice",
        "name": "BNPL Is Credit Now: What the Licence Means in Practice",
        "isPartOf": {
          "@id": "https://www.astrislaw.com/#website"
        },
        "mainEntity": {
          "@id": "https://www.astrislaw.com/article/bnpl-credit-licence-in-practice#article"
        },
        "inLanguage": "en-AU"
      },
      {
        "@type": "Article",
        "@id": "https://www.astrislaw.com/article/bnpl-credit-licence-in-practice#article",
        "headline": "BNPL Is Credit Now: What the Licence Means in Practice",
        "description": "From June 2025 buy now pay later sits inside the national consumer credit regime, with providers required to hold an Australian credit licence and apply a modified responsible lending framework. The licence is the visible change. What it does to product design, funding and partnerships is the real one.",
        "image": "https://www.astrislaw.com/images/articles/banking.jpg",
        "datePublished": "2026-08-07",
        "dateModified": "2026-08-07",
        "author": {
          "@type": "Person",
          "@id": "https://www.astrislaw.com/attorney/jamie-nuich#person",
          "name": "Jamie Nuich",
          "jobTitle": "Legal Practitioner Director",
          "url": "https://www.astrislaw.com/attorney/jamie-nuich",
          "sameAs": [
            "https://www.linkedin.com/in/jamienuich/",
            "https://www.qls.com.au/register-of-solicitors/jamie-leanne-nuich",
            "https://www.youandthelaw.com.au/organisation/98611/astris-law-pty-ltd"
          ],
          "hasCredential": [
            {
              "@type": "EducationalOccupationalCredential",
              "credentialCategory": "Professional License",
              "name": "Admission to Practice",
              "recognizedBy": {
                "@type": "Organization",
                "name": "Supreme Court of Queensland"
              }
            }
          ],
          "affiliation": {
            "@type": "LegalService",
            "@id": "https://www.astrislaw.com/#organization",
            "name": "Astris Law",
            "url": "https://www.astrislaw.com"
          }
        },
        "publisher": {
          "@id": "https://www.astrislaw.com/#organization"
        },
        "about": {
          "@type": "LegalService",
          "name": "Regulatory & Compliance",
          "serviceType": "Regulatory & Compliance"
        },
        "mainEntityOfPage": {
          "@id": "https://www.astrislaw.com/article/bnpl-credit-licence-in-practice#webpage"
        },
        "isPartOf": {
          "@id": "https://www.astrislaw.com/#website"
        },
        "speakable": {
          "@type": "SpeakableSpecification",
          "cssSelector": [
            ".article-summary",
            ".article-description"
          ]
        },
        "inLanguage": "en-AU",
        "wordCount": 1054,
        "timeRequired": "PT6M",
        "articleSection": [
          "Insights",
          "Regulatory & Compliance"
        ],
        "keywords": "Regulatory & Compliance, Insights, regulatory, compliance, consumer, law"
      },
      {
        "@type": "BreadcrumbList",
        "itemListElement": [
          {
            "@type": "ListItem",
            "position": 1,
            "name": "Home",
            "item": "https://www.astrislaw.com"
          },
          {
            "@type": "ListItem",
            "position": 2,
            "name": "Articles",
            "item": "https://www.astrislaw.com/articles"
          },
          {
            "@type": "ListItem",
            "position": 3,
            "name": "BNPL Is Credit Now: What the Licence Means in Practice",
            "item": "https://www.astrislaw.com/article/bnpl-credit-licence-in-practice"
          }
        ]
      },
      {
        "@type": "FAQPage",
        "@id": "https://www.astrislaw.com/article/bnpl-credit-licence-in-practice#faq",
        "mainEntity": [
          {
            "@type": "Question",
            "@id": "https://www.astrislaw.com/article/bnpl-credit-licence-in-practice#faq-1",
            "name": "Does every BNPL provider need an Australian credit licence?",
            "acceptedAnswer": {
              "@type": "Answer",
              "text": "From June 2025 buy now pay later sits inside the national consumer credit regime and providers are required to hold an Australian credit licence. Whether a specific product is caught turns on the substance of the arrangement, which is exactly why the analysis should be done on your actual product rather than on its category name."
            }
          },
          {
            "@type": "Question",
            "@id": "https://www.astrislaw.com/article/bnpl-credit-licence-in-practice#faq-2",
            "name": "What is the modified responsible lending framework?",
            "acceptedAnswer": {
              "@type": "Answer",
              "text": "It is the adapted responsible lending settings that BNPL providers must apply under the reforms. What it requires of a specific product is a design question that depends on the product and the arrangement, and it is worth resolving with advice rather than by analogy to a competitor."
            }
          },
          {
            "@type": "Question",
            "@id": "https://www.astrislaw.com/article/bnpl-credit-licence-in-practice#faq-3",
            "name": "My product is instalments but not marketed as BNPL. Am I affected?",
            "acceptedAnswer": {
              "@type": "Answer",
              "text": "Possibly. The perimeter turns on substance and rights, not labels, and it is technology neutral. A product that behaves like credit can be treated as credit whatever it is called. The position is worth testing before someone else tests it."
            }
          },
          {
            "@type": "Question",
            "@id": "https://www.astrislaw.com/article/bnpl-credit-licence-in-practice#faq-4",
            "name": "We distribute BNPL as a merchant or platform. Does any of this reach us?",
            "acceptedAnswer": {
              "@type": "Answer",
              "text": "The reforms changed the regulatory character of the product you distribute, and that changes what your distribution arrangements should deal with. The exposure depends on the arrangement, which is a reviewable document rather than a mystery. If your product sits in or near the credit perimeter, the cheapest time to know is now. Read more on our payments licensing page , Contact Astris Law for a fixed fee consultation or call (07) 3519 5616 ."
            }
          }
        ]
      }
    ]
  }
]
```