The Buy Now Pay Later Code should be revised to clarify its suitability criteria for offering BNPL products and to introduce commitments around unsolicited credit limit increases. These are among the 51 recommendations Promontory Australia has included in a review of the code commissioned by the Australian Finance Industry Association. In a statement on Friday, the AFIA said it supports all the recommendations. The association is lobbying hard to persuade the government to adopt a strengthened self-regulatory model for the BNPL sector, rather than regulation under the Credit Act. The Promontory review, which was led by former ASIC commissioner Peter Kell, will be promoted by the association as the blueprint for stronger self-regulation. Promontory has also recommended that the code encourage members to be more proactive in dealing with vulnerability and introduce specific commitments to assist people experiencing hardship. It recommended that the definition of “act fairly and honestly, be ethical and treat you reasonably” be clarified by providing examples of what this means in practice. It wants the code to include provisions that ensure consumers have better access to information about such things as repayment schedules, fees, transaction statements and suitability assessments. And it called for changes that will facilitate the processing of early repayments and credit limit reduction requests, and make complaints processes easier.  The Buy Now Pay Later Code of Practice was developed by the AFIA and introduced in March 2021. It has seven signatories: Afterpay, Brighte, humm, Klarna, Payright, Plenti and Zip. As well as recommending changes to the code, Promontory said it identified areas where administration of the code and compliance could be improved. “Whatever principles and promises a code may contain, it is the application of these in practice that will determine whether a code is effective,” the review said. “Our review found that there is significant room for improvement on this front. Some areas would benefit from more focus on compliance to ensure that the promises being made to customers are consistently delivered.” “There was evidence of inconsistencies and deficiencies in how some of the key code provisions are being applied in practice.”