Annual Review 2022–23

1,668 complaints were received
1,496 complaints were closed
69% of complaints were resolved at Registration and Referral stage

Stage at which BNPL complaints closed 



At Registration and Referral


At Case Management  


At Rules Review  


Preliminary Assessment  





Top five BNPL complaint issues (received)



Unauthorised transactions


Credit enquiry


Service quality


Financial firm failure to respond to request for assistance


Incorrect fees/costs



Time taken to close BNPL complaints



Closed in 0–30 days  


Closed in 31–60 days  


Closed in 61–180 days  


Closed in 181–365 days  


Closed in in more than 365 days  


Key insights

  • Buy now pay later (BNPL) complaints rose 57% from 1,064 in 2021–22 to 1,668 in 2022–23. AFCA is closely monitoring complaint trends in this area, given the recent increase in complaints.
  • BNPL providers are currently subject to less onerous legal obligations than other credit providers, meaning there is less scope for legal breaches that may give rise to complaints, and fewer requirements around the collection and reporting of complaints. BNPL providers are also not required to be AFCA members, so AFCA’s complaints data in this area is not representative of the entire industry.
  • BNPL products and their providers are expected to be the subject of new regulation in the near future. At present, regulation of BNPL is comparatively lighter than for credit products, including that a firm can provide BNPL services in Australia without being a member of AFCA. Some BNPL providers are members of AFCA on a voluntary basis and others are not. Complaint collection and handling practices vary widely between providers. BNPL transactions are also typically smaller amounts, which resolve earlier in the AFCA process.

BNPL complaints rose 57% in 2022–23. AFCA closed 1,032, or 69%, at the initial Registration and Referral stage, with an average closure time of 48 days. The main complaints in descending order were unauthorised transactions (218 or 13%), credit enquiries (177 or 11%), and service quality (150 or 9%).

The increase in BNPL complaints this year, suggests this will be an area requiring more focus in the current and future financial years. Similar to other credit-related complaints at AFCA, this increase reflects ongoing cost-of-living pressures as consumers seek alternative lines of credit to navigate stretched budgets. As with all credit providers, we hope to see BNPL firms actively considering requests for hardship assistance to support vulnerable customers.

The growing popularity of BNPL products and the subsequent increase in complaints to AFCA also underline the importance of the Australian Government’s plan to regulate BNPL under the National Consumer Credit Act 2009 (Cth). AFCA welcomes the Government’s proposal to enhance the regulation of BNPL, and will look to operationalise any change required in our membership or process. Some BNPL providers seek to meet credit provider obligations already, and we encourage firms to consider uplifting their internal dispute resolution and other processes ahead of any regulatory change.

Case study – Hardship obligations and BNPL products


The complainant had a buy now pay later (BNPL) account with a financial firm that was closed due to an unpaid outstanding balance. Her complaint to AFCA centred on concerns that when the account was active, she was homeless and did not have a job due to experiencing domestic violence.

The complainant had contacted the financial firm to raise concerns about the amounts owing on the account (on the basis they were incurred by her ex-partner), and said she was advised the account would not be suspended if she made payments towards it.

The BNPL obligations

The account is not a regulated credit facility and, therefore, is not subject to the National Consumer Credit Act. However, under the BNPL Code, the financial firm had obligations to:

  • focus on its customers and their needs
  • be fair, honest and ethical in its dealings with its customers
  • act with transparency and keep its customers informed about its products and services
  • treat customers fairly, respectfully and consider their specific circumstances if they are experiencing financial hardship
  • train its staff to identify signs of vulnerability, such as where there may be mental health illness or issues, or domestic and family violence concerns.

Complaint outcome

In a Preliminary Assessment, AFCA found the financial firm was entitled to suspend the BNPL account. However, AFCA’s case worker found that the financial firm breached the Debt Collection Guideline and its BNPL obligations, as follows:

Debt Collection Guidelines

Under clause 13 of the Debt Collection Guidelines, financial firms have an obligation to cease collection on a debt where there is disputed liability.

AFCA found that the financial firm was reasonably on notice that the complainant was disputing some of the debt. This was supported by the financial firm’s own call notes, which stated: ‘Advice orders were made by ex-partner.’ Therefore, until it had made further enquiries, the firm should have ceased collecting money owed. AFCA concluded the firm had not done so, Evidence from the financial firm revealed a payment plan to the complainant without reviewing the claim of disputed liability.

BNPL obligations

AFCA found the financial firm failed to comply with BNPL obligations as it did not appropriately consider or explore the complainant’s specific circumstances when hardship was raised. The financial firm’s call notes explicitly stated that the complainant was unemployed, but the firm failed to make adequate enquiries into her ongoing financial position and instead offered her a payment plan, which the complainant felt compelled to agree to, without exploring the complainant’s ability to meet the repayments.

AFCA found the financial firm failed to act in a fair and reasonable manner by not considering the complainant’s specific circumstances and vulnerabilities. There were indicators that should have prompted the firm to take steps to better understand and handle her situation with more care.


AFCA awarded $1,500 in non-financial compensation to the complainant for stress and inconvenience.

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