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Target Market Determination



Elevare Pay Easy Pty Ltd A.C.N. 634 728 591 (Elepay) (we, us or our) issues PayLater products to Australian Property Owners and we are committed to maintaining a consumer-centric approach throughout our product design phase, distribution and sales channels, and monitoring and review process.  This Target Market Determination (TMD) is effective as at 15 June 2023.  


1.  Purpose of this TMD


This TMD has been prepared by Elepay for its ‘12-Months Product’ in compliance with our Design and Distribution Obligations
under Part 7.8A of the Corporations Act 2001 (DDO).

This TMD sets out the class of consumer for which the 12-Months Product Product has been designed having regard to the
objectives, financial situation and needs of consumers in the product’s target market. It includes the following:

  • product features and class of consumers that fall within the target market;

  • distribution conditions, restrictions and sales practices that are likely to direct distribution of the Products to the target market;

  • information relating to reviews and monitoring of the Products and this TMD, including specifying timing for periodic reviews and review triggers (i.e., the events or circumstances which would trigger a review);

  • how we deal with significant dealings.

This TMD does not offer a comprehensive outline of the 12-Months Product Product’s terms and conditions, nor is it a substitute for obtaining independent legal or financial advice. Consumers should read the full terms and conditions before applying for the  Product.

2. Background to the 12-Months Product

The 12-Months Product is part of a suite of PayLater Products Elepay offers to Australian Property Owners who intend to style, renovate or improve their real property through Elepay’s exclusive 12-Months partners. The aim of this product is to allow Australian Property Owners the opportunity to enhance their property whilst providing additional time for them to repay associated property-related costs.

An “Australian Property Owner” includes:

  • any person or entity who is a registered proprietor to real property held in Australia (Owner);

  • any person or entity who is an appointed representative of an Owner (e.g. appointed attorney or executor of a deceased estate); or

  • any person or entity who has the express consent of the Owner to acquire the 12-Months Product relating to the Owner’s
    property (for example, Elepay may require the registered proprietor to sign a Deed of Consent).


To offer the 12-Months Product, we have partnered up with a number of styling, renovation and refurbishment companies to allow property owners to defer payment of expenses relating to:

  • home renovation and improvement;

  • property styling (to keep) and refurbishment; 

  • other property-related works,

       (Property-related Costs).

3. Class of consumers that comprises the Target Market

The 12-Months Product is designed exclusively for consumers who meet our Eligibility Criteria and who wish to defer payment of their upfront Property-related Costs over a period of 12 months (Target Market). No foreseeable monetization event is required for a consumer to obtain the 12-Months Product. 


The 12-Months Product is for the class of consumers who: 

  • falls within the definition of Australian Property Owner (see above) and require short-term lending solutions to pay Property-related Costs;

  • are seeking finance with flexible payment options, only a capped processing fee of $125 per annum and no interest for the term of the loan^, the ability to make early repayments without additional charges, and a maximum amount of funding capped at the amount of the Property-related Cost;  

  • are receiving products or services and incurring Property-related Costs through our 12-Months Partners; 

  • otherwise meets Elepay’s Eligibility Criteria (set out below);

  • are not currently experiencing financial hardship;

  • are able to make twelve (12) equal instalments every 30 days (in arrears) to repay the loan amount, without causing financial hardship.


The 12-Months Product is not suitable for consumers who:

  • do not fall within the definition of Australian Property Owner;

  • are not receiving products or services and incurring Property-related Costs through our 12-Months Partners; 

  • do not otherwise meet Elepay’s Eligibility Criteria;

  • are going through bankruptcy or are experiencing, or are likely to, suffer from financial hardship;

  • are considered vulnerable persons (e.g. suffering from any form of cognitive impairment);

  • require an ongoing line of credit;

  • require a redraw facility;

  • are not comfortable with providing security over their real property.

^Default interest and other fees apply, see below.

Eligibility Criteria and Other Product Key Attributes


To be eligible for the 12-Months Product, a consumer must satisfy the following requirements:  

  • be an individual aged 18 years or above; 

  • fall within the definition of Australian Property Owner (see above);

  • meet Elepay’s standard lending criteria including: 

    • conducting a credit check on the consumer; 

    • conducting an identity verification check on the consumer; 

    • conducting an ownership check (including title search of the property); 

    • conducting an online property valuation report (for the property);

  • satisfy the following credit assessment criteria, which will be conducted by Elepay’s Finance Specialist Team:

    • Property Equity Analysis, which is a credit assessment based on the net equity-debt risk analysis of the consumer’s property;  

    • Income Serviceability Analysis, which is a credit assessment based on the consumer’s household net income and which ensures that the consumer has the financial capability to make the required repayments without experiencing financial hardship. The consumer must satisfy Elepay’s internal serviceability assessment calculator. The consumer will be required to: 

(a)   complete an income serviceability form outlining their net household income and expenses; 
(b)   provide supporting documentation for any claimed source(s) of income (e.g. 2 recent pay slips); and 
(c)   disclose any existing (or anticipated) circumstance or event which may affect their ability to make the required repayments;

  • be incurring Property-related Costs through our approved 12-Months Partners of a minimum amount of $100.00.


Some key attributes of the 12-Months Product include: 

  • Structure –the 12-Months Product is structured so that: 

    • Elepay enters into a loan with the Consumer with a loan term of 12 months, under which Elepay disburses funds directly to the 12-Months Partner for payment of Property-related Costs incurred by the consumer (from the Partner); 

    • the consumer has in total 12 months from the Elepay Start Date to repay the loan (in full); 

  • Purpose of loan - the 12-Months Partner must be providing products or services to the Consumer and the loan must be 
            for the payment of the Partner’s Property-related Costs (whether partial or in full); 

  • Repayment– the consumer must repay the loan by way of twelve (12) equal instalments payable every 30 days (in 
            arrears), though early repayment is possible without penalty (see below); 

  • Partner’s goods or services – the Partner has an obligation under its Partner Agreement with Elepay to supply goods and services to the consumer with reasonable care and skill and in accordance with the supply terms between the Partner and the consumer; 

  • Fee Structure – the Fee structure for the 12-Months Product is as follows:

    • No Plan Fee and no Interest for the term of the loan – the Consumer is not required to pay any plan fee or interest for
      the provision of credit (default interest and other fees apply, see below);

    • No Establishment or Administration fee – the Consumer is not required to pay any establishment or administration fee
      for the provision of credit;

    • Capped Processing Fee – the Consumer is required to pay a capped processing fee of $125.00 per annum, which is spread equally across the twelve instalments; 

    • Partner Fee – the Partner is required to pay a partner fee of up to 7.95% of the consumer’s total loan amount. This fee
      is payable under a separate agreement between Elepay and the Partner;

    • Default/Late fee – the consumer will be liable to pay a late interest of 0.0695% per day compounding daily (of the
      outstanding amount) and a late fee of 0.25% every 30 days (of the outstanding amount) if the consumer has not
      repaid an amount owing by the scheduled repayment date. This is subject to any claim the consumer may have for
      financial assistance.

    • Other fees – other fees may apply such as a missed payment fee ranging from $15.00 to $25.00 (depending on the nominated method of payment) and title registration fee ranging from $350 to $1,100 (depending on whether a registered security is provided with respect to the consumer’s property); 

  • Minimum Credit Limit – the minimum amount of funding provided is $100.00;

  • Maximum Credit Limit – subject to an individual credit and lending assessment for a particular consumer, the amount of funding provided is capped at the Property-related Costs agreed between the consumer and the 12-Months Partner;

  • Early repayments – Consumers have the ability to make an early repayment of the loan without any additional charge
    or exit fee;

  • Security – the consumer will be required to provide a charge over the consumer’s real property (which may or may not
    be registered against title to the property).

4. Consistency between the Target Market and the Product Key Attributes

​Set out below is our assessment of the likely objectives, financial situation and needs of the Target Market, and the key product attributes of the 12-Months Product.   

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5. Distribution Channels and Conditions


Elepay considers it is reasonable to conclude that if the 12-Months Product is issued to a consumer in accordance with the distribution conditions in this TMD it would be likely that the consumer is in the Target Market and it would likely be consistent with their likely objectives, financial situation and needs. This determination is based on the assessment above regarding the consistency between the Target Market and the Product’s Key Attributes, which incorporates past outcomes and feedback of the Product’s consumers and Partners. 


Distribution Channel: A consumer may only apply for our 12-Months Product via our approved 12-Months Partners (Distributors). 

We have oversight over how the 12-Months Product is promoted and issued. 

We regularly monitor our 120RLC Partners’ websites and marketing material to ensure they contain:

  • no misleading information;

  • all relevant disclosures and warnings required by law;

  • an easy to follow process during which the consumer is given informed choices at every stage.

Our own website contains:

  • no misleading information;

  • all relevant disclosures and warnings required by law;

  • an easy to follow process during which the consumer is given informed choices at every stage.

The distribution conditions relating to the marketing and promotion of the 12-Months Product are specified in the table below.   

6. Periodic Review and Review Triggers

To ensure that the 12-Months Product continue to meet the objectives and needs of its Target Market, it is necessary that we regularly review this TMD. This includes consideration of: 

  • 12-Months Product and Target Market;

  • Eligibility Criteria; and

  • distribution channels and conditions.

In reviewing the above, we collect and analyse data relating to:

  • our eligibility and application phase;

  • Partner feedback and our online Partner portal;

  • disputes between the Partner and consumer relating to the Partner’s services and products;

  • sales information;

  • customer information;

  • payment information (including funds recovered and not recovered);

  • feedback and complaints (from consumer and Partners);

  • default information and extended repayment terms;

  • property sale status (including the amount of property withdrawn from sale);

  • market conditions (including the effect of interest rate changes and market sentiment).

These reviews will be conducted periodically and in response to review triggers and other events or circumstances that would
reasonably suggest this TMD is no longer appropriate.


We will conduct our next review on the Next Review Date and periodic reviews at least six monthly
from the Next Review Date.



In addition to periodic reviews, we will review this TMD in response to a review trigger or other event or circumstance that
would reasonably suggest this TMD is no longer appropriate. The occurrence of a review trigger or other such event or
circumstance will trigger an immediate review of this TMD and may result in Elepay changing the Target Market, the design or
distribution of the product or ceasing to offer this product.

These review triggers are:


  • we receive a substantial number of complaints from consumers or partners about the 12-Months Product (i.e., if complaints
    about the product from active 12-Months Product  consumers or partners increases by 10% or more in a six month period);

  • a substantial number of consumers are:

    • experiencing negative repayment history, including missing a scheduled repayment (i.e., if over 15% of active 12-Months Consumers fall within this category); 

    • seeking financial hardship relief (i.e., if over 10% of active 12-Months Product consumers fall into this category); 

  • there are material changes to the key attributes of our products which may result in the product no longer being
    appropriate for our Target Market;

  • there is a material change in our distribution channels such that our distribution conditions requires variation;

  • there are a substantial number of complaints relating to the Product or services provided by the Partner (e.g. delay in works completed by the Partner) (i.e., if complaints about our partners from active 12-Months Product consumers increases by 10% or more in a six month period);

  • change in regulatory, legislative or market conditions which may materially affect the product or any matter relating to
    this TMD;

  • the use of Product Intervention Powers, regulator orders or directions about or relating to the 12-Months Days Product’s key features, target market or distribution strategy;

  • a significant dealing has occurred (or is likely to occur). A significant dealing occurs when the distribution of our product
    (including conduct by our distributors) significantly differs from any condition or expectation set out in this TMD;

  • any other matter that may result in this TMD not being appropriate.

7. Reporting

We will report to ASIC within ten (10) business days should we have reasons to believe that a significant dealing has occurred
either by us or via our distributors. Our distributors are also obliged to inform us of any significant dealing events, and we have
arrangements in place to monitor and review our distributors’ compliance with this obligation.

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We will also monitor other consumer and distributor feedback on a monthly basis.

8. Records

We will keep records of any complaints, action taken or review of any matters related to this TMD.
This includes, but is not limited to:

  • Product design and development matters;

  • Data collected and analysed for TMD reviews;

  • TMD review meetings;

  • Consumer and distributor feedback; and

  • Review of distribution channels and conditions.

9. Contact

Should you have any queries regarding this TMD, please contact us at or 1300 019 417.

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