Financial Counselling Victoria welcomed the opportunity to provide feedback on the Exposure Draft materials proposing to regulate buy now, pay later products (BNPL) as credit. This is a joint submission made on behalf of the following organisations:

• CHOICE
• Financial Rights Legal Centre
• Consumer Action Law Centre
• Indigenous Consumer Assistance Network
• Brotherhood of St Laurence
• The Salvation Army
• Financial Counselling Australia
• Financial Counselling Victoria
• Consumer Credit Legal Service
• Redfern Legal Centre
• LawRight

Our organisations have long advocated for BNPL to be regulated as a credit product under the National Consumer Credit Protection Act 2009 (NCCPA), and so we welcome the major step towards achieving this outcome that the Exposure Draft materials (ED Materials) represent. We urge the Government to finalise this legislation as a matter of priority to ensure that the framework is passed this year.

This submission contains 30 recommendations aimed at improving the ED Materials so they will better achieve their stated objectives.