When a BNPL provider wants to be a member of the Code of Practice, the CCC undertake a detailed and rigorous process to understand their
business and ensure that they can meet the industry standards as set out in the Code.
The process of accreditation includes providing information to the CCC on their systems and processes, to show how it will comply with the Code.
This includes sharing documentation on their complaint handling and hardship policies, information about their upfront and existing customer assessments, and their merchant guidelines and
The BNPL provider also needs to show they have appropriate risk management arrangements for their business and have adequate arrangements for
compensating BNPL customers.
If the BNPL provider is able to demonstrate to the CCC that they are able to comply with the Code, they become a ‘Code Compliant Member’ or Code Signatory. This means they can display an accreditation symbol
in the relevant places on their documents and website.
As part of their ongoing role in administering the Code, the CCC will collect information and data from the Code Compliant Members on a regular
basis to ensure that they continue to meet the required standards. The CCC will determine what information should be collected, but it is likely to include information on complaints, hardship
and merchant monitoring.
The CCC can also receive complaints from customers about 'Alleged Breaches' of the Code by a Code Complaint Member.
The CCC is authorised to investigate complaints lodged and as part of that are granted access to all relevant records required to carry out the task. Code Compliant Members are required to
cooperate with these investigations and comply with all reasonable requests. Following the submission and review of a complaint, the CCC have the power to make a range of recommendations to
resolve a complaint and have powers to impose a range of sanctions.