Medium Amount Credit Contract

Updated 12 Mar 2026Content was accurate at the time of publication

A medium amount credit contract (MACC) sits between short, high-cost payday style loans and larger consumer credit products. This practical guide explains what a MACC is, the statutory thresholds that define it, the regulatory framework credit providers must follow, and the steps borrowers should take if something goes wrong.

What is a medium amount credit contract?

A medium amount credit contract (MACC) is a regulated consumer credit contract under the National Consumer Credit Protection (NCCP) framework. In statutory terms a MACC is a consumer credit contract that:

is for an amount greater than $1,000 and not more than $1,000, and
has a maximum term that typically exceeds short-term loan limits, commonly up to 2 years depending on product design and regulatory settings.

The MACC category was introduced to capture mid-range, unsecured loans that pose different consumer risks from both small amount credit contracts (SACCs) and larger personal loans. Key features to note:

MACCs are subject to the NCCP Act's responsible lending obligations and credit licensing rules.
Fee arrangements and disclosure requirements differ from SACCs; MACCs are not subject to the same SACC fee caps, but regulators require clear disclosure and suitability checks.
MACCs may be unsecured personal loans or secured by consumer assets; regulatory duties apply regardless of security.

For a quick comparison to other loan types see the table in "How MACC differs from small and large credit contracts". For authoritative legislative definitions consult ASIC, Treasury and the NCCP Act listed under Further reading.

Legislative and regulatory background

MACCs sit inside the NCCP Act framework and are regulated through legislation, regulations and ASIC/Treasury instruments:

Primary law: National Consumer Credit Protection Act 2009 (NCCP Act) — establishes consumer credit licensing, responsible lending duties and disclosure requirements.
Regulatory agency: Australian Securities and Investments Commission (ASIC) — issues regulatory guides, class orders and enforces compliance.
Policy instruments: Treasury explanatory materials and regulations implement specific definitions and fee or term settings for categories such as SACCs and MACCs.
Product governance: Designated products may require a Target Market Determination (TMD) under product-governance frameworks; ASIC provides guidance for credit products.

Key reform timeline includes establishment of the NCCP Act nationwide licensing and responsible lending duties, refinement of product categories to better align consumer protections for mid-value loans, and ASIC's focus on affordability checks, disclosure and avoiding unconscionable lending practices.

Key obligations for lenders and credit providers

Lenders that enter into MACCs must comply with statutory and regulatory obligations. Below is a practical summary for compliance officers, brokers and product teams.

Credit licensing and authorised activities

Lenders must hold an Australian credit licence (ACL) to engage in credit activity unless an exemption applies. They must keep licence conditions current, maintain ACL records and ensure brokers provide credit assistance only as authorised representatives.

Responsible lending duties

Lenders must make reasonable inquiries into a consumer's financial situation, objectives and needs and assess whether the MACC is unsuitable. They must verify income, living expenses, existing liabilities and capacity to repay without substantial hardship.

Common compliance failures include relying solely on unverifiable statements, cursory affordability checks, or ignoring red flags such as multiple concurrent short-term debts.

Disclosure requirements

Lenders must provide pre-contract disclosure documents required by the NCCP Act, including key facts statements, credit contracts and credit guides. Disclosures must be clear, prominent and provided within statutory timelines before contract formation.

Target Market Determinations

If a MACC product is designated under product governance rules, lenders must prepare and retain a TMD. TMDs should specify the target consumer cohort, distribution conditions, restrictions, review triggers and monitoring arrangements. Lenders must keep TMD records and evidence of distribution checks.

Fees, interest and permitted charges

MACCs are not subject to SACC fee caps but must disclose APR, establishment fees, ongoing fees, default charges and termination costs. Fee schedules should be prominent and the total repayable amount calculated clearly.

Hardship and variation obligations

Lenders must maintain a documented hardship procedure and consider requests for variation, deferral or temporary relief promptly. They must keep records of applications, decisions and follow-up communications.

Compliance checklist for lenders

Hold and maintain an ACL.
Document affordability verification steps and retain source documents (pay slips, bank statements).
Provide full pre-contract disclosures and keep proof of delivery.
Prepare and retain product TMDs where required.
Maintain complaints logs, hardship records and internal dispute resolution files.
Run regular TMD and distribution reviews and keep monitoring evidence.
Train staff on MACC-specific obligations and escalation pathways.

How MACC differs from small and large credit contracts

A side-by-side snapshot helps you identify where protections and risks change.

Feature	Small amount credit contract (SACC)	Medium amount credit contract (MACC)	Larger personal/consumer loans
Typical loan amount	≤ $2,000	> $2,000 and ≤ $5,000	> $5,000
Typical max term	Short (e.g., ≤ 62 days)	Usually up to 2 years	2+ years
Fee caps	Strict SACC fee caps and default limits	No SACC-style caps; disclosure required	Standard consumer law disclosure and interest rules
Responsible lending	Yes, with additional short-term protections	Full responsible lending duties apply	Full responsible lending duties apply
Common examples	Payday style cash loans	Mid-range unsecured personal loans	Car loans, mortgages, larger personal loans

Enforcement, penalties and regulator action

Regulators use a range of enforcement tools where credit providers breach the NCCP Act or ASIC guidance. Typical responses include:

Civil penalties and pecuniary fines.
Enforceable undertakings requiring remediation and compliance programs.
Banning orders against individuals and firms.
Court orders for refunds, rescission or compensation.
Criminal prosecution in cases involving fraud or wilful breaches.

ASIC has prioritised irresponsible lending and misleading conduct in consumer credit. ASIC enforcement examples have included remediation programs where affordability assessments were inadequate or disclosure failed. Practical outcomes observed in enforcement actions include refunds or remediation payments to affected customers, requirements to rewrite policies and improve staff training, and significant monetary penalties for systemic breaches.

What this means for borrowers

If you're considering a MACC or already in one, follow these steps to protect your interests:

Check amount and term: Verify the loan amount (> $1,000 and ≤ $1,000) and confirm the contract term in months.
Read pre-contract disclosure carefully: Confirm APR, total repayable, fees and default charges.
Ask about affordability checks: What documents did the lender obtain? If none were obtained, flag this.
Keep evidence: Save emails, SMS, bank statements, copies of the key facts sheet and signed contract.
Use hardship provisions early: Request hardship assistance in writing and retain copies.
Seek independent help: Financial counsellors and legal centres can assist with dispute letters and AFCA complaints.

If you're unsure whether a product is a MACC, compare the loan amount to the thresholds for small amount credit contracts and larger loans, and ask the lender to confirm the product's classification and TMD if any.

Common scenarios and examples

Scenario 1 — $1,500 personal loan, 18-month term

A broker arranges a $1,500 unsecured loan for 18 months. This falls inside MACC thresholds. The credit provider must perform full affordability checks, provide pre-contract disclosure and retain evidence of the borrower's financial situation. If the lender relied only on the borrower's statements without documentary verification, the contract may be vulnerable to dispute.

Scenario 2 — Lender fails to consider existing short-term debts

A borrower has multiple SACCs but is approved for a MACC without aggregated debt assessment. Responsible lending requires consideration of existing liabilities and cumulative repayment burden. Borrowers should request the lender's assessment details; lenders must document how concurrent debts were factored into suitability.

Scenario 3 — Hardship request ignored

A borrower requests temporary variation due to illness and hears nothing for weeks. Lenders must have a hardship process and respond within a reasonable time with reasons for denial. Preserve evidence of the request date and time, and escalate internally; lack of response can be part of an AFCA complaint.

Each scenario underscores the importance of documentation—both for borrowers preserving their rights and for lenders demonstrating compliance.

How to complain or seek redress

If you suspect non-compliance, follow this step sequence to preserve options and evidence:

Contact the lender: Request internal dispute resolution (IDR) in writing and keep a copy. Ask for a written explanation of decisions and copies of documents relied upon.

Use external dispute resolution: If unsatisfied with IDR, lodge a complaint with AFCA.

Report to ASIC: If conduct appears systemic, misleading or criminal, lodge a report with ASIC via their consumer complaint channels.

Seek free advice: Contact a financial counsellor or community legal centre for assistance drafting complaint material.

Preserve evidence: Keep copies of the contract, disclosures, correspondence, bank statements, proof of payments and hardship requests.

Consider legal advice: For complex disputes involving large sums or potential court action, consult a lawyer.

FAQ

Is a payday loan a MACC?

Typically no. Payday or SACC products are usually ≤ $2,000 and short term; MACCs are higher value (>$2,000 and ≤ $5,000) and longer term.

Can a MACC be rolled over?

Rolling over may mask unaffordability. Lenders must still comply with responsible lending obligations for any new or varied contract and must disclose changes. Hardship processes may be more appropriate.

How long do lenders have to keep TMD records?

TMDs and related distribution records must be kept for the period required under Corporations/credit rules, typically several years. Exact retention periods are set out in TMD guidance and ASIC regulatory guides.

What evidence helps if contesting a lender's suitability assessment?

Pay slips, bank statements, rental or mortgage statements, bills, copies of existing loan contracts, correspondence and proof of any hardship requests.

Can AFCA order refunds for MACC breaches?

Yes. AFCA can recommend or decide remedies including refunds, compensation or contract variation depending on the facts and eligibility.

Are MACCs covered by the NCCP responsible lending test?

Yes. MACCs are consumer credit contracts and fall within the NCCP responsible lending framework requiring suitability and verification.

Who can help me if I can't afford repayments?

Start with the lender's hardship team. If unresolved, contact a financial counsellor or community legal centre such as Financial Rights, and consider AFCA if the lender's response is inadequate.

What are common red flags compliance teams should monitor?

Minimal documentation for income, repeated short-term lending patterns, failure to consider concurrent SACCs, incomplete TMD reviews, and poor complaint handling.

Key takeaways

Medium amount credit contracts are regulated consumer loans for $1,000–$1,000 available over typically up to 2 years, subject to full NCCP responsible lending, licensing and disclosure requirements. Borrowers should verify loan classification, request affordability evidence and use hardship processes when needed. Lenders must document all compliance steps, maintain TMDs where required and respond promptly to hardship requests or face AFCA complaints and enforcement action by ASIC.