Target Market Determination

1. About this document

This Target Market Determination (TMD) is required under section 994B of the Corporations Act 2001 (Cth). This TMD seeks to offer consumers an understanding of the class of consumers for which this product has been designed, having regard to the objectives, financial situation and needs of the target market.


This document is not to be treated as a full summary of the product’s terms and conditions and is not intended to provide financial advice. Consumers must refer to the relevant terms and conditions available at when deciding to use this product.


This TMD applies to the Inkpay product and is effective from 5 October 2021.


2. Class of customers that fall within this target market

The information below summarises the Inkpay product overall class of consumers that fall within the target market for its buy now, pay later plan, based on the product key attributes and the objectives, financial situation and needs that it has been designed to meet.


The Inkpay buy now, pay later 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 Inkpay buy now, pay later plan is for consumers who are seeking an affordable no interest finance solution that enables them to pay for goods and services to make their financial situation sustainable and manageable.


This product is designed for consumers who:

  • Is an Australian resident and receive their income paid into an Australian bank account. 
  • Is 18 years of age or older. 
  • Is not experiencing financial hardship. 
  • Is seeking a low cost, fixed fee, short-term credit product that is not revolving. 
  • Do not have an established credit history and may have other liabilities.
  • Require a product with strong inbuilt controls. 
  • Require an instalment plan to help manage the timing of personal finances, including unexpected expenses and/or expenses beyond the affordability of their pay cycle.


Excluded class of consumers

This product has not been designed for individuals who:

  • Want a product with a large upfront spending limit.
  • Want unrestricted spending.
  • Want access to cash.
  • Want to use the buy now, pay later plan for a purpose other than the purchase of goods and/or services provided by accredited partners in Inkpay’s distribution channel.
  • Do not want to use financial technology applications.
  • Currently have a suspended or terminated Inkpay account.
  • Do not have an ability to make the repayments.
  •  Are in financial hardship or likely to become financially strained by the product


Eligibility requirements 

Consumers must successfully complete the onboarding process by meeting the following requirements:

  • Be an individual who is at least 18 years old.
  • Be capable of entering into a legally binding contract.
  • Be an Australian resident, who can verify their identity for Anti-Money Laundering (AML) / Counter- Terrorism Financing (CTF) legislation purposes.
  • Have a valid email address and mobile telephone number.
  • Be able to pay 40% of an order amount immediately as the first instalment
  • Be the authorised holder of an Australian-issued credit card, or debit card linked to an Australian bank account, or Australian bank account; Provide accurate and complete information about yourself as prompted by our website or mobile app.
  • Be able to access the product or service through digital means.
  • The individual must accept Inkpay’s Terms and Conditions and Privacy Policy (both of which can be accessed here) in Australia.
  • Not have had an account which was terminated for outstanding payments or for breaching and/or violating an agreement attached to your Account or another Inkpay Account we believe you had.


Product attributes

  • Pay in four instalments over six to eight weeks.
  • No charging of interest.
  • No annual, account keeping or establishment fees.
  • Variable spending limit based on customer good repayment history and capabilities and inability to spend over the set limit.
  • An entirely digital pathway – 1) application process, 2) receiving documents, and 3) viewing/updating account details can all be completed online.
  • 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.
  • No charging of late fees when the customer pays on time.
  • Capping of late fees.
  • Freezing of late fees for customers who apply for hardship.


Consistency between target market and the Product

This product is consistent with the objectives, needs and financial situation of the class of consumers in the target market.


This is based on an analysis of the key attributes, features and terms of the product, including its design, with the identified needs of the class of consumers. As the product has been designed for consumers who want to pay for tattoos with no upfront or annual fees, no interest, fixed repayments and an ability to self-serve their account, the product design enables this form of repayment schedule and access.


Additionally, because the product has been designed for those who are able to meet the repayments of the purchase amount over the term of the payment plan, the individual must be over the age of 18 and have the means to make the repayments in accordance with the repayment schedule. The digital product protects customers at risk by proactively offering hardship assistance and preventing them to continue to spend on their Inkpay account whilst they have remaining payments scheduled. Inkpay conducts regular monitoring to identify common characteristics who regularly make hardship request or incur late fees.


3. How this product is to be distributed

Inkpay has defined the permitted distribution channels it uses and associated distribution conditions or restrictions. These conditions will be reviewed if distribution channels change.


Distribution channels

Inkpay is designed to be distributed through the following:

  • By digital means on Inkpay’s mobile app.
  • By Inkpay’s platform as a payment option in-store for participating merchants.
  • By using Inkpay’s platform as a payment option through participating merchants’ websites.


Distribution conditions

Inkpay should only be distributed under the following conditions:

  • To individuals that meet the eligibility criteria.
  • To individuals that have the financial capacity to repay the principal balance of the Inkpay instalment plan.
  • Through Inkpay’s approved distribution channels.


Adequacy of distribution conditions and restrictions

Inkpay 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 for. The eligibility criteria are adequate in supporting the distribution of the product in accordance with objectives, financial situation and needs set out above.


4. Review schedule for TMD

Initial review to be completed no later than 5 October 2022


Periodic reviews

At least every two years from the initial review.


Review triggers or events

 Any event or circumstances arise that would suggest the TMD is no longer appropriate. This may include (but not limited):


  • Material changes to the design or distribution of the product, including related documentation.
  • Occurrence of a significant dealing outside the target market.
  • External events such as material adverse media coverage or regulatory attention.
  • A significant change in metrics, including, but not limited to, late repayments, complaints, sales volumes, hardship, and arrears.
  • Product design or implementation failures.
  • Inconsistency of distribution with the TMD.
  • Feedback received (including complaints).
  • Potential or actual harm to consumers.


Where a significant change in a review trigger has occurred resulting in a significant dealing, this TMD will be reviewed within 10 business days. Inkpay will notify ASIC in writing within 10 business days of it forming a view that a significant dealing in the product has occurred and not consistent with the TMD.