Wage Advance Target Market Determination
Effective date: 2 October 2021
Last updated: 29 June 2026
This Target Market Determination (TMD) has been prepared by Wagepay Pty Ltd (ABN 15 645 114 629), and its subsidiaries (“we”/”us”/”our”). This TMD is for our Wage Advance product (the Product).
1. What is a Target Market Determination?
A Target Market Determination (TMD) describes the class of consumers (Target Market) for which this Product has been designed, having regard to their objectives, financial situation, and needs. A TMD also describes matters relevant to the Product’s distribution and review.
This TMD should not be treated as the product terms and conditions and does not constitute financial advice. When making a decision about this Product, customers should refer to the Wage Advance Credit Contract, which sets out the terms and conditions that apply to the Product.
2. About this TMD
This TMD describes:
- the key attributes and features of the Product;
- the Target Market, i.e. the class of customers that the Product is suitable for;
- how the Product attributes meet the Target Market needs;
- the Product distribution conditions;
- review periods for the TMD;
- events or circumstances which may trigger a review for this TMD; and
- the information we need to decide if the TMD is no longer appropriate.
3. Product Description
The Product is a short-term credit product designed for customers who require additional funds to cover regular and ongoing or one-off expenses that cannot be paid from their current wages or pay cycle as part of their employment. The Product is issued by a special purpose vehicle entity, Wagepay SPV1 Pty Ltd (ACN 660 236 779), that enters into the contract for the Product with customers.
4. Product key attributes and features
The key attributes and features of the Product are:
- the provision of credit amounts ranging from $100 to $3,000;
- a credit term of 2 to 62 days;
- a maximum flat fee of 5% as an establishment fee charged on the day of advance;
- a maximum annual interest rate of 24% with interest calculated daily;
- no missed payment or default fees;
- accessed via mobile app or web browser portal only;
- simple account setup process, completed by most customers within 3 minutes;
- completely automated credit assessments, with most completed in under 2 minutes;
- funds are transferred using the New Payments Platform (NPP) (99% of payments) and are processed in real time, most within 60 seconds;
- self-service account management tools available in the mobile app; and
- transparent, legible and easily understood contract, including schedule and terms.
For full details of the terms and conditions of the Product, please refer to the Wagepay Advance Credit Contract.
5. Who is the Target Market for this Product
The Product has been designed for a class of consumers who require additional funds to pay for regular and ongoing expenses that, for whatever reason, cannot be paid using the customer’s wage or income for this pay cycle. We rely on customers to identify their pay date.
The Target Market are the persons that meet the criteria below. The Product has not been designed to meet the needs, objectives, and circumstances of persons not in the Target Market.
| Key Criteria | Suitable for customers who: | Not suitable for customers who: |
| Age | • are over 18 years old. | • are under 18 years old. |
| Income | • are employed on a full-time or part-time basis or whose income source are not solely Centrelink Benefits; and • earn at least $500 or more per week. | • are unemployed or temporarily out of work; • whose only source of income are Centrelink Benefits; or • earn less than $500 per week. |
| Bank account | • are paid income into an Australian bank account; and • are paid into a bank account held in their own name. | • are paid income in cash; or • are paid income into a bank account in another person’s name. |
| Documentation | • are able to provide electronic copies of their bank account statements via bank feeds. | • are only able to provide paper bank statements. |
| Require a short-term product | • require short-term credit to be repaid in a future pay cycle; • only need a maximum term of no more than 62 days; and • need amounts between $100 and $3,000. | • require a credit product that will have a medium or longer term (more than 62 days); • need amounts greater than $3,000; or • need to repay inside the same pay cycle. |
| Require cashflow | • need to pay for purchases and expenses, which may be regular and ongoing, and which, for whatever reason, they cannot pay for from their disposable income in a given pay cycle; and • where we have formed a reasonable belief that the customer is likely to be able to afford the repayment on the Product on or after their next pay date. | • do not consider there is value in having the Product; • where we have not been able to form a reasonable belief that the customer is likely to be able to afford the repayment on the Product on or after their next pay date; or • where we have not been able to form a reasonable belief that the customer is likely to be able to meet the costs of the Product, including the establishment fee or interest charges which may be payable. |
| Fast digital service | • want the account setup process to be fast and the credit transferred quickly; • want the advance process to be completely online or via mobile app; and • want ready access to self-service options and perform customer service requests online. | • want to request the credit in a store or branch; • want access to a call centre for customer service; or • do not require the funds quickly or immediately. |
The Product has been designed for customers whose objectives, financial situation and needs are described below:
| Objectives | Customers seeking additional funds to cover regular and ongoing or one-off expenses that, for whatever reason, cannot be paid from their current wages or pay cycle. |
| Financial situation | Customers where we have formed a reasonable belief that the customer is likely to be able to afford the repayment on the Product. |
| Needs | Customers who: • Seek cashflow in between payment cycles for the payment of ongoing or one-off expenses; • Are seeking short-term credit (up to 62 days) for small amounts (between $100 and $3,000), with repayment on or after their next pay date; • Want a service which is relatively easy and quick to set up and access; • Want fast access to funds within a short-period of assessment; and • Want a fully digital end to end service. |
6. Distribution channels and conditions
The Product is distributed through the following channels:
- Our own mobile app and web browser portal, with marketing and advertising conducted via digital marketing, social media and referrals.
The following conditions apply to how the Product is distributed.
- Only we can distribute the Product to our customers and it must be distributed to the Target Market in accordance with this TMD.
- Our staff have knowledge of the Product, its benefits and conditions and understand the Target Market for this Product.
The distribution channels and conditions make it likely that our customers to whom we distribute the Product are within the Target Market because the conditions are supported by reasonably appropriate design and distribution controls.
7. Scheduled reviews
We will conduct periodic reviews of this TMD to ensure that it is appropriate for the Target Market. The first review will take place 1 year from the Effective Date of this TMD and then we will review this TMD annually from the date of the last review to ensure it is still appropriate.
When we review this TMD, we will consider information which we collect. This information includes:
- Product data (for example, provided credit amounts, terms, fees and interest rates);
- Eligibility criteria data (for example, income source levels, employment status, customer age);
- Default Data;
- Feedback and complaint information;
- Hardship and payment plan information;
- Product review outcomes; and
- Dealings of product outside of the TMD.
8. Review triggers
Certain events and circumstances taking place could mean that a review should take place earlier than the scheduled reviews. This is because these events and circumstances may reasonably suggest that the TMD is no longer appropriate or the Product is no longer consistent with the likely objectives, financial situation and needs of the people in the Target Market. These events and circumstances are called review triggers. Below is a list of review triggers for this TMD:
| Product changes | We make a significant change to the Product, including the: • terms and conditions; • eligibility criteria; and • way it is offered and distributed. |
| Target Market changes | There is a relevant and significant change or event affecting a reasonable proportion of people in the Target Market (e.g. a change in law or regulation). |
| Suitability metrics | Changes to our Product suitability metrics suggests that the TMD is no longer appropriate. These are reviewed on a quarterly basis, and includes but is not limited to the: • percentage of total advances in arrears; • percentage of new customer advances in arrears; • percentage of first payment direct debit dishonours in the period; • number of advances written off as a percentage of advances in the period; • number of complaints in the period; and • number of complaints as a percentage of advances in the period. |
| Complaints | There is a pattern of complaints or feedback which may: • relate to the appropriateness of the Product for the Target Market. • suggest that customers do not see value in the Product. • suggest that the Product is not performing appropriately for the Target Market. We record all complaints that we receive about the Product and will review them on a quarterly basis. |
| Legal and regulatory | There is a change in law, regulatory guidance or industry code which may materially affect the terms of the Product or its distribution, or regulatory feedback or concerns or media attention that materially affects the design or distribution of the Product and suggests the TMD may no longer be appropriate. |
| Regulator and external dispute resolution feedback | Feedback, orders or directions from a regulator or external dispute resolution body suggests the TMD is no longer appropriate. |
| Dealing outside of the Target Market | Data suggests that: • we have been selling the Product to people outside the Target Market. • the Product is being distributed outside of the Target Market. |
| Significant dealings | A significant dealing in the Product occurs, for example a significant number of customers who are not in the target market are approved for the Product. |
In determining whether a significant dealing has occurred that is outside of the target market, the factors we may take into account include (but are not limited to):
- The number of people who obtain the Product and are not within the Target Market including the proportion of people excluded from acquiring the Product;
- The nature and extent of the distribution inconsistent with the TMD;
- The proportion of gross income obtained from the Product in respect of people who are not in the Target Market;
- The time period in which these acquisitions outside the Target Market occurred; and
- The monetary loss incurred to those who are not in the Target Market.
If we decide we have enough information to identify that a review trigger has occurred, we will review this TMD as soon as possible, and in any event within 10 business days of our decision.
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