Australian Securities & Investments Commission publishes Regulatory Guide 281 to prepare buy now pay later providers for 10 June 2025 low cost credit contract reforms

The Australian Securities & Investments Commission (ASIC) has issued Regulatory Guide 281 Low cost credit contracts (RG 281) to help buy now pay later (BNPL) providers understand and comply with their obligations ahead of new laws taking effect on 10 June 2025. The guide focuses on the compliance framework for BNPL contracts that meet the definition of a low cost credit contract, including the operation of modified responsible lending obligations. RG 281 follows ASIC’s February consultation (Consultation Paper 382) and incorporates changes in response to 16 stakeholder submissions, including clarifications and additional examples. The guidance sits alongside the Treasury Laws Amendment (Responsible Buy Now Pay Later and Other Measures) Act 2024, which amends the National Consumer Credit Protection Act 2009 to extend the National Credit Code to BNPL contracts. ASIC reiterated that BNPL providers that do not already hold the appropriate credit licence should apply as soon as possible, warning that providers whose licence application has not been accepted for lodgement by 10 June 2025 may be engaging in unlicensed conduct if they continue to operate.