61% of Investing SMEs Now Plan to Use a Non-Bank, Up From 19% in 2019. The Payday Super Answers Were Collected in July — the Month the Rule Started

ScotPac’s latest SME Growth Index puts the share of investing small and medium businesses that intend to use a non-bank lender at 61% — a record for the series, and more than triple the 19% recorded in 2019. Over the same period, the share planning to fund new investment through their main relationship bank or a peer sat at 31%, down from a peak of 48% in 2023.

If you write commercial or asset finance, that number is the headline. But it is not the most useful number in the release, and the most useful number is not a funding statistic at all. It is a date: the fieldwork closed in July 2026 — the month Payday Super commenced. Almost everything the index records about Payday Super is therefore anticipation, captured before a single quarter of the new regime had been lived through.

That gap between what SMEs expected in July and what their bank statements will show by mid-2027 is where the broker opportunity actually sits.

1. What the index found

The SME Growth Index is a twice-yearly survey run for ScotPac by consultancy East & Partners. The September 2026 round interviewed 727 SMEs with annual revenue between $1 million and $20 million. As reported by Broker Daily, respondents had been operating for an average of roughly 16.6 years and employed about 50 full-time equivalent staff.

• 59% of those surveyed planned to invest over the next six months.
• 61% of that investing group said they would use non-bank finance to do it — the record figure, up from 19% in 2019.
• 31% intended to use bank lending, against a 48% peak in 2023.
• 32% intended to raise new equity, up from 11% in 2014.
• A record 16% of businesses forecasting flat or declining revenue said they did not know which funding method they would use.

SME investment intentions have remained steady for the past five years with two-thirds of SMEs planning to invest; however, the way businesses are choosing to finance that investment has changed.Clare Morgan, Chief Executive, ScotPac

On why businesses are making that choice, Morgan pointed to “flexibility, greater choice, speed of decisions and ongoing support that reflects their circumstances.”

2. The number underneath the headline

The non-bank figure gets the coverage. The figure that should change how you read a business file is this one: as reported by Broker Daily, 97% of investing businesses expect to use internal funds or equity for at least part of new investment over the next six months — up from 81% in 2014.

These categories are not exclusive. A business can intend to use a non-bank facility and fund most of the investment from retained cash, and on these numbers most of them do. The practical reading is that growth is still being paid for out of working capital first, with external finance filling the remainder.

Using retained funds to invest in growth may make sense in some scenarios, but businesses need to ensure that investment does not compromise day-to-day liquidity.Clare Morgan, Chief Executive, ScotPac

3. What Payday Super actually requires

Because this is the mechanism doing the work, it is worth stating from the ATO’s own guidance rather than from summaries of it.

From 1 July 2026, employers must pay super so that it is received by the employee’s super fund, with enough information to allocate it to the employee’s account, within 7 business days after each payday, to avoid the super guarantee charge. Contributions are calculated at 12% of qualifying earnings — a term that covers ordinary time earnings such as wages and salary, paid leave, allowances and bonuses; all commissions; salary sacrifice amounts that would otherwise be superable; and payments to workers under the extended definition of employee, including eligible independent contractors.

Two mechanical details that matter more than they look

• The receiving fund has 3 business days to allocate or reject a contribution, and that window does not include the day the contribution is received.
• There is no extension to the 7-business-day deadline if a payment is rejected by the fund.

Where a payment is late, the super guarantee charge applies. The ATO assesses it, so the employer does not lodge a statement; it includes interest that compounds daily plus an administrative uplift, and penalties of 25% or 50% of the unpaid charge can apply depending on any prior penalties. A longer period is available in limited cases, such as the first contribution for a new employee.

4. The timing caveat the coverage skips

Australian Broker reported the index’s Payday Super findings in detail: about 26% of SMEs said they were fully prepared or expected no material cash-flow impact; 83% of smaller SMEs expected a negative impact against 64% of larger ones; 37% intended to seek an external funding facility, with 16% pointing to payroll funding and 10% to invoice finance. East & Partners’ own summary of the round put it as almost three in four SMEs facing severe cash-flow impacts from the change.

Those figures appear in that reporting rather than in a primary release we were able to read, so treat them as that outlet’s account of the round. Australian Broker also reported an analysis by Lend suggesting Payday Super could reduce SME borrowing capacity by up to 15% — an analyst’s estimate, attributed as such, not an established figure.

Now put the fieldwork date against it. The survey closed in July 2026. Payday Super started on 1 July 2026. Respondents were describing a regime they had been inside for days, not quarters. The 26% who felt prepared had not yet tested their payroll software against a fund rejection on day six. The 74% expecting problems had not yet found out whether those problems were real.

5. What this does to a business file in 2027

The business bank statements you read from about the March 2027 quarter onward will look structurally different from the ones you read a year earlier — not because the business changed, but because the timing of one liability did.

Smoother but thinner

Quarterly super lumps disappear; a steady fortnightly or monthly outflow replaces them. Average balances fall even where turnover is flat. A serviceability read that keys off minimum or average balances may understate a business that is simply paying the same amount more often.

New arrears, new causes

Super guarantee charge interest compounds daily. A business that misses deadlines for administrative reasons — a payroll system misconfiguration, a rejected contribution late in the window — can accumulate a liability that looks like distress on paper but started as a process failure. Those are different credit conversations, and the file should distinguish them.

ATO exposure is already large

The Australian National Audit Office, in Auditor-General Report No. 45 2025–26 on the ATO’s management of small business collectable debt, found that small business collectable tax debt was $35.9 billion of $54.2 billion in total collectable debt in 2024–25, and concluded that “the ATO’s management of collectable small business debt is partly effective.” Australian Broker also reported that 20% of surveyed SMEs named tax and compliance costs as their leading cash-flow pressure. An existing ATO arrangement is a material fact on a commercial file regardless of what Payday Super does next.

6. Where the Best Interests Duty reaches — and where it does not

ASIC’s RG 273 is explicit about scope. RG 273.5 states that “the best interests obligations apply only in relation to credit products that are regulated under the National Credit Act” — products provided for personal, domestic or household purposes, or for the purchase or improvement of residential investment property. A genuine business-purpose working capital facility is not regulated credit, and the duty does not reach it.

That is a statement about scope, not a lower standard. Two points follow.

First, the boundary is decided by the actual purpose and structure of the credit, not by the label on the application or a declaration on the file. Where a business cash-flow problem is solved with credit secured over a client’s home, whether the duty applies turns on that characterisation — which is exactly the question to take to your licensee before lodgement rather than after.

Second, for the regulated work you do, RG 273 has something to say about panel breadth. RG 273.112 requires a broker to be satisfied that the credit products they can access and recommend are sufficient to act in consumers’ best interests, and RG 273.113 states that “you should be accredited with a reasonably representative panel of credit providers.” RG 273.115 goes further: if you are not satisfied your accessible products will let you act in a consumer’s best interests, you must not provide credit assistance to that consumer. If a growing share of client demand is moving toward lenders you hold no accreditation with, that is worth reviewing on its own terms.

7. What to review this week

1. Segment your commercial and self-employed book by employee count. The 83%/64% split reported by Australian Broker suggests pressure is not evenly distributed. Employers with staff are the cohort to call first.
2. Ask one question on every business fact-find: how often do you run payroll, and is super going out with it? A fortnightly cycle with super still batched is the file most likely to meet the super guarantee charge.
3. Add contractor arrangements to your questions. Qualifying earnings reach payments to workers under the extended definition of employee, including eligible independent contractors.
4. Re-read recent business statements for the pattern, not the balance. Falling average balances with flat turnover may be the timing change, not deterioration. Note which it is.
5. Check your panel against where demand is going. Payroll funding and invoice finance were the two facilities SMEs pointed to most. If you cannot place either, that is an accreditation gap.
6. Treat ATO positions as a standing question. Given the scale the ANAO reported, an existing payment arrangement is common enough to ask about as a matter of course.
7. Take characterisation questions to your licensee early. Business purpose versus regulated credit decides which obligations attach.

Sources: ScotPac SME Growth Index, September 2026 round (research conducted by East & Partners), as reported by Broker Daily (26 October 2026), East & Partners (28 October 2026) and Australian Broker (6 November 2026); Australian Taxation Office guidance on Payday Super and paying super for your employees; Australian National Audit Office, Auditor-General Report No. 45 2025–26, Australian Taxation Office Management of Small Business Collectable Debt; ASIC Regulatory Guide 273, Mortgage brokers: Best interests duty; Reserve Bank of Australia cash rate decision, 3 November 2026. Figures identified above as a single outlet’s reporting are attributed to that outlet rather than stated as established fact.