35% of BNPL Enquiries Come From Clients With No Recent Credit Activity. On Active Files, 20% Sit Behind a Prior Adverse Event

Most brokers already run a private rule on buy now pay later. Some treat it as noise — small balances, short terms, nothing a credit assessor will die on. Others treat it as a warning light and start rehearsing the conversation about closing accounts before submission. Bureau data published this week says both rules share the same flaw: they assume BNPL is one signal. It is two, and which one you are looking at depends entirely on what else sits on the record.

What the Experian split actually found

Experian A/NZ’s July Business Pulse Monthly Spotlight, reported by The Adviser on 3 September, tracked consumer credit enquiries across a six-month window and separated BNPL enquiries according to whether the consumer had other recent credit activity. Three findings do the work.

First, BNPL is where a large share of Australians make their first recorded credit move. Thirty-five per cent of BNPL enquiries came from consumers with no recent credit activity — more than double the equivalent share for personal loan enquiries at 17 per cent, and well ahead of credit card enquiries at 13 per cent.

Second, that group escalates less, not more. Twenty-nine per cent of credit-inactive consumers in the BNPL cohort made a subsequent credit enquiry within six months, compared with 35 per cent for both the credit card and personal loan cohorts. On new accounts the gap is wider: just 4 per cent of credit-inactive consumers whose first recorded enquiry was for BNPL opened a new credit account within six months, against 8 per cent in both other cohorts.

Third — and this is the finding that changes a file — the picture inverts among consumers who were already credit-active. Twenty per cent of BNPL enquiries in that group involved someone with a previous delinquency or adverse credit event, against 13 per cent for credit card enquiries and 14 per cent for personal loan enquiries.

Read together, the three findings describe one product doing two unrelated jobs. For a consumer with no bureau history, a BNPL enquiry is an entry point — and, on this data, a comparatively quiet one. For a consumer already carrying credit, the same enquiry sits in a cohort where prior adverse events are recorded at roughly half again the rate of the mainstream products.

Why BNPL now behaves like credit on your files

This would be an interesting statistic and nothing more if BNPL were still sitting outside the credit framework. It is not. The low cost credit contract reforms commenced on 10 June 2025, and from that date anyone engaging in credit activities involving BNPL contracts has been required to hold an Australian credit licence with the appropriate authorisations, and to be a member of AFCA. ASIC released Regulatory Guide 281, Low cost credit contracts, to support the transition in May 2025.

The consequence for brokers is quieter than the headline was. BNPL is now provided by licensed credit providers operating inside the National Credit Code, which is why bureau enquiry data of the kind Experian analysed exists in the first place. A BNPL enquiry is no longer something that lives only in a client’s bank statements and their memory. It is increasingly a visible part of the credit footprint you and the credit assessor are both looking at.

That cuts both ways. It means less can be quietly overlooked. It also means a client who has never held a card or a personal loan may now arrive with something on file where five years ago there would have been nothing at all.

The assessment asymmetry most brokers have not priced

Here is the part that rarely gets discussed at PD days. Under RG 281, providers of low cost credit contracts may elect to comply with modified responsible lending obligations rather than the standard ones. The modified regime is a genuine assessment framework — providers must still assess unsuitability, must maintain a written unsuitability assessment policy, and must make inquiries about income, expenditure and other credit products. But it is calibrated to the size of the contract.

Two features of that calibration matter to you. RG 281 describes a rebuttable presumption that contracts of $2,000 or less meet the consumer’s requirements and objectives. And the credit-checking requirement scales: smaller contracts attract a negative credit check, while contracts at and above the $2,000 threshold attract additional consumer credit liability information.

The flip side is the one worth taking to your next difficult file. A credit-active client with several small BNPL facilities has not necessarily been through anything resembling a full capacity assessment on any of them. If the instalment debits are material against income, the number that matters is the aggregate commitment and the conduct on it — not the fact that a licensed provider said yes.

Two clients, two conversations

The thin-file entrant

This is the client the 35 per cent figure describes: no recent credit activity, a BNPL enquiry as the first recorded move. Often a younger borrower, a recent arrival, or someone who has simply never needed a card.

Your problem here is evidentiary, not behavioural. On Experian’s data this cohort is less likely than card or personal loan enquirers to take on further credit in the following six months. What they lack is the demonstrated repayment history a credit assessor is used to reading. The productive conversation is about building a verifiable picture: a rent ledger, a savings pattern that survived a rate rise, account conduct across twelve months, employment stability. A short, clean BNPL history is a small positive here, not a blemish — provided the repayments landed on time and you have documented that they did.

The credit-active user

This client already has a record, and the BNPL enquiry sits alongside it. The 20 per cent figure is not a verdict on your client — it is a cohort statistic — but it tells you where the questions should go. Multiple concurrent instalment facilities, BNPL usage that has increased over the statement period, or instalment debits clustering immediately after pay cycles are all things a credit assessor will read as a pattern. Better that you read it first, understand the reason, and address it in the file rather than have it surface in a conditional approval.

The distinction between “this client uses BNPL for convenience and clears it monthly” and “this client is using BNPL to smooth a cash flow that does not balance” is not visible in the credit file. It is visible in the statements and in the conversation. That is broker work, and it is exactly the work the best interests duty contemplates.

What this data does not license you to do

Three limits are worth stating plainly, because summary statistics have a way of hardening into desk rules.

• This is one bureau’s dataset, reported by one outlet. The figures come from Experian A/NZ’s July Business Pulse Monthly Spotlight as reported by The Adviser. They are not a market-wide measurement and not a regulator’s finding.
• These are cohort figures, not predictions about an individual. Eighty per cent of BNPL enquiries among credit-active consumers did not involve a prior adverse event. Treating a BNPL line as a proxy for a credit problem would be wrong four times out of five, and would be a poor basis for a recommendation.
• Nothing here is a lender policy change. No lender has announced a new treatment of BNPL commitments on the back of this data. If you want to know how a particular lender treats instalment facilities in servicing — as a commitment, at a notional limit, or not at all — that remains a question for their policy team or your BDM, and the answer still varies materially across a panel.

Where it lands: BID and the file note

The best interests duty does not tell you what to think about BNPL. It does shape what you do when a file contains something you cannot yet explain.

ASIC’s RG 273 sets out the expectation that brokers gather information about the consumer, including their reasons for approaching you and what they are seeking to achieve, alongside the requirements and objectives and financial situation information gathered for responsible lending purposes. The guide goes on to address the situation where initial disclosures are not enough: brokers should make further inquiries where instructions are unclear or appear inconsistent with the consumer’s circumstances, should seek complete and accurate information where gaps are apparent, and should refrain from making a recommendation where critical information cannot be obtained.

A pattern of instalment credit that does not sit comfortably with a stated expense position is, on any reasonable reading, the kind of inconsistency that invites a further question. RG 273 also notes ASIC’s expectation that evidence of compliance will come predominantly from the broker’s own records — which is the whole argument for writing down what you asked and what the client said, rather than resolving it silently in your head.

This is general information rather than compliance advice. Obligations under the National Consumer Credit Protection Act 2009 and ASIC’s guidance apply to your specific circumstances and your licensee’s own policies will be more prescriptive than anything published here. Confirm your process with your aggregator or licensee’s compliance team.

What to review this week

The bottom line

The value in this week’s data is not that BNPL is riskier than brokers thought, or safer. It is that the single line on a credit file has stopped being a single thing. One version of it belongs to a client at the very start of a credit history, who on this evidence is unusually unlikely to escalate. The other belongs to a client whose cohort carries prior adverse events at meaningfully higher rates than card or personal loan enquirers.

You already have the tool that tells them apart. It is the rest of the credit file, the twelve months of statements, and a question asked properly at the fact-find. What has changed is that there is now published evidence for why that question is worth asking — and, if a file is ever reviewed, why you asked it.

Sources: Experian A/NZ July Business Pulse Monthly Spotlight, as reported by The Adviser, “BNPL data reveals divergent consumer credit journeys”, 3 September 2026 · ASIC media release 25-069MR, 8 May 2025 · ASIC Regulatory Guide 281 Low cost credit contracts · ASIC Buy now pay later credit contracts: Credit licensing · ASIC Regulatory Guide 273 Mortgage brokers: Best interests duty.