Target Market Determination

1. About this document

This target market determination (TMD) is effective from 05.10.2021 and defines the class of consumers for which the Openpay product (alternatively, also referred to as an Openpay Plan) has been designed, having regard to the likely objectives, financial situation and needs of the target market.

This document is not to be treated as a full summary of an Openpay Plan’s Terms and Conditions and is not intended to provide financial advice. Consumers must refer to the Terms and Conditions and any supplementary documents which outline the relevant terms and conditions under the product, when making a decision about this product.

This TMD provides Openpay’s customers with information regarding:

  • which customers this product is suitable for (the target market) and which customers this product is unsuitable for;
  • any distribution conditions and restrictions on distribution for this product; and
  • the review period and events or circumstances that may trigger a review.

This TMD describes the customers within our target market, but does not consider a customer’s personal needs, objectives or financial situation.

1.1. Openpay Plan Terms and Conditions

This TMD applies to the Openpay Plan referred to in the following Terms and Conditions:

Openpay Terms and Conditions

2. Class of consumers that fall within Openpay’s target market

The information below summarises the overall class of consumers that comprise the target market for the Openpay Plan, based on the product key attributes and the objectives, financial situation and needs that it has been designed to meet.

The Openpay Plan has been designed for consumers whose likely objectives, financial situation and needs (as listed below) are aligned with the product (including the key attributes). The Openpay Plan is for those individuals who want to spread the cost of the things they want and need over time, with no hidden fees.

2.1. Key Eligibility Requirements and Product Attributes

The Key Eligibility Criteria of the Openpay Plan are:

  • The individual must be over the age of 18 years and hold a valid Australian payment card.
  • The individual must have a valid email address and mobile number.
  • The individual must be a resident of Australia.
  • The identity of the individual must have been verified for Anti-Money Laundering (AML) / Counter-Terrorism Financing (CTF) legislation purposes.
  • The individual must accept Openpay’s Terms and Conditions and Privacy Policy (both of which can be accessed here) in Australia.

The product attributes of the Openpay Plan are:

  • Customers may select the start date and frequency of repayments among the payment plans available for each merchant.
  • If the customer meets all the above Key Eligibility Criteria, the customer is assigned a spending limit equal to or less than $1000 AUD. If the customer is requesting an amount greater than $1000 AUD, additional checks are required.
  • There is no interest for the Openpay Plan. There are fees clearly set out in the Terms & Conditions, are displayed prior to the creation of the Openpay Plan, and which are capped per annum.

2.2. Objectives and needs

The Openpay Plan has been designed for individuals who:

  • Want to spread the cost of a purchase over time.
  • Want to align their repayments with their cash inflows for budgeting purposes.
  • Want to make repayments by interest-free instalments with no hidden fees.
  • Want longer, flexible plan options relative to other providers.
  • Want to make repayments without missing an instalment or experiencing hardship.
  • Need to receive an instant approval decision to gain access to the buy now pay later facility.
  • Need to access buy now pay later facilities in-store or online through approved merchants.
  • Want to use buy now pay later facilities to make purchases across the range of merchants with whom Openpay partners.
  • Want to manage their finances from one easy mobile app, and access a large range of Openpay merchant partners.

2.3. Financial situation

The Openpay Plan has been designed for individuals who are able to:

  • Pay the purchase amount in accordance with the instalment payment schedule they select.
  • Meet the instalment payment schedule including all fees without experiencing hardship.
  • Benefit from the unique advantages offered by the Openpay Plan.

2.4. Excluded class of consumers

The Openpay Plan has not been designed for individuals who:

  • Want access to cash via a credit facility.
  • Want a physical payment card to make purchases.
  • Want to use buy now pay later facilities for the purposes of procuring products and services such as gambling, mainstream alcohol, bullion, arms and ammunition
  • Want to use buy now pay later facilities where there are legal and / or regulatory restrictions on finance being provided to purchase goods or services
  • Need to repay the purchase amount over a period longer than 24 months.
  • Are unable to meet the instalment schedule including all fees without experiencing hardship.
  • Are unable to be verified for AML / CTF purposes.

2.5. Consistency between target market and the product

The Openpay Plan is designed to support the likely objectives, needs and financial situation of the class of consumers in the target market. This is based on an analysis of the key terms, features and attributes of the product and an assessment that these are consistent with the identified class of consumers.

As the Openpay Plan has been designed for individuals who need flexible payment options, the product has the ability to be paid via multiple weekly or fortnightly instalments depending on the merchant providing the product or service. Similarly, as the Openpay Plan has been designed for individuals who are able to pay the purchase amount, the individual must be over the age of 18 and hold a valid Australian payment card.

Openpay has committed to the Australian Finance Industry Association (AFIA) Buy-Now-Pay-Later Code of Practice (Code) and will only provide the product where we can satisfy ourselves that we will meet our obligations under the Code to do so.

3. How this product will be distributed

3.1. Distribution channels

Openpay distributes its own product via the following means:

  • Directly through Openpay’s mobile app.
  • Providing the Openpay platform as a payment option in-store for participating merchants.
  • Providing the Openpay platform as a payment option through participating merchants’ websites.

3.2. Distribution conditions

This product should only be distributed under the following conditions:

  • To individuals that meet the Key Eligibility Criteria.
  • Through Openpay’s approved distribution channels.
  • Where there are any consumer queries or concerns, where they have been answered by an authorised Openpay representative.

3.3. Adequacy of distribution conditions and restrictions

Openpay distributes its own product and has determined that the distribution conditions and restrictions will make it likely that the consumers who purchase the product are in the class of consumers for which it has been designed. The Key Eligibility Criteria is considered to be adequate in supporting the distribution of the product in accordance with objectives, financial situation and needs set out above.

4. Reviewing, Monitoring and Reporting this TMD

Initial ReviewBy October 5, 2022.
Periodic ReviewsPeriodically, and at least annually commencing October 5, 2022.
Review Triggers or Events
  • Any event or circumstances that would suggest the TMD is no longer appropriate. This may include but is not limited to:
  • a material change to the design or distribution of the product, including related documentation;
  • occurrence of a significant dealing;
  • regulatory change affecting the buy-now, pay later industry;
  • material percentage of consumer payment defaults with the Openpay Plan;
  • material complaints, AFCA determinations or litigation relating to the Openpay Plan;
  • external events such as adverse media coverage or regulatory attention; and
  • significant changes in review triggers covering matters such as:
    • inconsistency of product with target market’s likely needs, objectives or financial situation;
    • product design or implementation failures;
    • inconsistency of distribution with the TMD;
    • feedback received (including complaints); and
    • potential or actual harm to consumers.
Regular MonitoringWhere a significant change in a review trigger has occurred resulting in a significant dealing, this TMD will be reviewed within 10 business days.
Significant DealingsOpenpay will notify ASIC in writing within 10 business days of it forming a view that a significant dealing in the product has occurred and which is not consistent with the TMD.