AWLabs

Loan origination and servicing software for Australian lenders

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The short answer

Loan origination software takes a credit application from submission to settlement: data capture, verification, decisioning, documents and funding, then hands the loan to servicing and collections. Most Australian non bank lenders should buy or configure an origination platform such as Simpology or NextGen's ApplyOnline tools and build only the parts that make them different: decision rules, broker portals, servicing views and hardship workflow. Every build must leave a decision record that shows responsible lending was met, and from 10 December 2026 automated decisions also bring Privacy Act transparency duties. Focused custom builds typically sit in the $30,000 to $150,000 (AUD, ex GST) market range, as a range, not a quote.

Key takeaways

  • Under responsible lending, a credit provider must make reasonable inquiries, take reasonable steps to verify, and make a final assessment that the contract is not unsuitable, with a written copy on request.
  • Since 10 June 2025, buy now pay later contracts are regulated credit, and providers need an Australian credit licence and AFCA membership.
  • AML/CTF changes for current reporting entities started on 31 March 2026, unless deferred under transitional rules.
  • From 10 December 2026, privacy policies must describe decisions made or substantially and directly assisted by computer programs that significantly affect individuals.
  • AWLabs holds no credit licence or AFSL. We build the systems; your licence holders and lawyers decide what the law requires.

What does a lender’s software stack cover?

A lending stack has four jobs: origination (getting the application in and verified), decisioning (approving, declining or referring), servicing (running the loan) and collections (managing arrears and hardship). Each job has different users, different data and different regulatory evidence.

StageMain usersTypical systemsEvidence it must keep
OriginationBrokers, applicants, credit staffOrigination platform, broker channel, identity and bank dataInquiries, documents, verification sources
DecisioningCredit assessors, riskRules engine, scorecards, bureau dataAssessment, rule version, overrides with reasons
ServicingOperations, customersLoan management system, customer portalStatements, variations, credit reporting data
CollectionsCollections and hardship teamsArrears workflow, payment arrangementsHardship requests and responses, contact history

Off the shelf platforms are strongest at origination and weakest where a lender’s own credit policy and customer experience live. That is where custom builds usually start.

Buy, configure or build?

For most non bank and private credit lenders the right answer is to buy or configure origination and build decisioning, broker experience and servicing tools around it. The Australian market has mature origination options. Simpology describes a mortgage origination platform covering electronic lodgement through Loanapp, a loan origination system with workflows from pre assessment to settlement, and a gateway to external services such as identity validation. NextGen’s ApplyOnline covers lodgement, origination, assessment and open banking across lenders, aggregators and brokers.

Use this rule of thumb when you scope:

  • Buy what every lender needs in the same way: lodgement, document capture, identity checks, bank data retrieval.
  • Configure what differs by product but fits the platform’s model: application journeys, document lists, workflow stages.
  • Build what is your competitive edge or your legal evidence: decision rules, broker portals, servicing views, hardship handling.

Our build vs buy guide explains the trade-offs in general terms.

What must the decision record show under responsible lending?

A credit provider must make reasonable inquiries about the consumer’s requirements, objectives and financial situation, take reasonable steps to verify that situation, and make a final assessment that the contract is not unsuitable, then be able to give a written copy of that assessment on request. ASIC sets out its expectations in RG 209, issued in December 2019.

A decision record that stands up should store, for every application:

  1. The data captured and where each item came from (applicant, broker, bureau, bank data, payslip).
  2. The verification step applied to each material item.
  3. The rule set or model version that ran, and its outputs.
  4. Any manual override, who made it and why.
  5. The final assessment, in a form you can hand to the consumer.
  6. The time each of these happened.

The common failure is not missing data but missing lineage: the assessment says income was verified, but nobody can show which document it was verified against. Build lineage in from the first release.

How do credit reporting rules shape the data model?

Credit reporting is governed by Part IIIA of the Privacy Act and the Credit Reporting Code, which tightly control what you can collect from and disclose to bureaus, how you use it and how you correct it. The main consumer bureaus are Equifax and Experian, and illion is now part of Experian.

Financial hardship information is a specific case. The OAIC notes that financial hardship arrangements and the associated financial hardship information are regulated by the Privacy Act, with strict rules on use and disclosure. Your servicing system must record hardship arrangements accurately because they flow into the repayment history you report. Treat credit reporting data as its own domain in the data model, with access limited to roles that need it.

What changed for BNPL and hardship?

From 10 June 2025, buy now pay later contracts became regulated credit under the National Credit Code, and anyone engaging in BNPL credit activities needs an Australian credit licence with the right authorisations and AFCA membership. The amendments also created low cost credit contracts as a new category, whose providers can elect modified responsible lending obligations.

Hardship volume makes workflow matter. Moneysmart reports more than 280,000 hardship notices across Australia in the 2024/25 financial year, and says a lender must consider a customer for hardship assistance when they ask. A hardship module should:

  • Capture the request from any channel, including phone and email, with the date received.
  • Pause collections activity where policy requires.
  • Track information requested and received, decisions made and timeframes.
  • Record the arrangement agreed and feed it to credit reporting correctly.
  • Give staff a full history so the customer doesn’t repeat their story.

How do broker channels connect?

The MFAA reports that brokers facilitate 81.6% of new residential home loans, so for a home lender the broker experience is part of the product. Broker applications typically arrive through ApplyOnline or Simpology rather than your own forms, then need status updates, conditions and document requests sent back.

A custom broker portal earns its place when your product needs information the standard lodgement data doesn’t carry, when you want to give brokers instant indicative decisions, or when you want to show live status and outstanding conditions without phone calls. Integration with the lodgement platforms is usually the first and largest piece of work.

Can AI make credit decisions?

It can contribute, but the lender stays accountable, the decision must be explainable, and from 10 December 2026 your privacy policy must describe how computer programs are used in decisions that significantly affect individuals. The automated decision transparency rules come from Schedule 1, Part 15 of the Privacy and Other Legislation Amendment Act 2024. A credit decision clearly affects a person’s interests, so lenders using automation should expect to be in scope.

Safer patterns for AI in lending:

  • Machine learning scores used inside hard policy rules, never instead of them.
  • Large language models used to read documents, such as payslips and bank statements, with every extracted value shown to an assessor for confirmation.
  • A full log of model version, inputs and output for every decision.
  • Regular checks for drift and for unfair outcomes across customer groups.

Our guide to the Privacy Act automated decision rules covers the transparency duty in detail.

What do the 2026 AML/CTF changes mean for lenders?

AUSTRAC says changes for current reporting entities, including to AML/CTF program requirements and customer due diligence, started on 31 March 2026 unless deferred under the transitional rules. Lenders that provide designated services such as loans are already reporting entities. AUSTRAC publishes a risk assessment and suspicious activity indicators for non bank lenders and financiers, which are useful inputs when you design onboarding checks and monitoring rules.

In system terms, plan for: customer due diligence results stored against each customer, ongoing monitoring rules with case management, and reporting workflows your compliance officer controls.

Does any of this apply to small business lending?

Responsible lending under the National Credit Act covers regulated consumer credit, so most small business loans sit outside it, but small business borrowers can still take complaints to AFCA within its jurisdiction. AFCA published its Lending to Small Business Approach in January 2024, alongside its Responsible Lending Approach. A lender with both consumer and business products needs product level rules about which obligations apply, set by its lawyers and enforced in the workflow.

What do typical builds cost?

These are indicative AUD market ranges, ex GST, not quotes. Expeed publishes $40,000 to $150,000 for mid complexity systems and $150,000 to $500,000 or more for enterprise solutions.

BuildIncludesIndicative range
Decisioning rules engine and audit logPolicy rules, bureau and bank data inputs, overrides, full decision lineage$50,000 to $150,000
Broker portalLodgement integration, status and conditions, document requests$40,000 to $100,000
Hardship and collections workflowMultichannel intake, case management, arrangements, credit reporting feed$30,000 to $80,000

How AWLabs approaches lending builds

We start with a Development Consult to understand your products and where the current stack falls short. A paid Discovery Audit then maps your platform’s integration options and the evidence each decision must leave, and you receive a fixed price Schedule of Work with three options: The Minimum, The Recommended and The Complete. Senior engineers lead every build, with updates every Tuesday and Friday, Sydney time.

AWLabs has not yet delivered a project for a lender and holds no credit licence or AFSL. This page is general information, not legal advice. See our enterprise software service and wider finance and fintech work.

Frequently asked questions

Should a lender build its own loan origination system?

Rarely all of it. Origination platforms carry document handling, broker channel links, identity and bank data integrations and regular regulatory updates. Most lenders get more value from configuring a platform and building what sets them apart: their decision rules, their broker experience and their servicing and hardship tools. A full build makes sense mainly for a new product type no platform handles well.

What does a responsible lending decision record need to contain?

Enough to show the inquiries you made, how you verified the information, and why you assessed the loan as not unsuitable, in a form you can give the consumer on request. In practice that means storing inputs, verification sources, the rule or model version used, any manual overrides with reasons, and the final assessment document, all tied to the application.

Can we use machine learning for credit decisions?

Yes, but you remain responsible for each decision and must be able to explain it. Keep models inside a rules framework that enforces hard policy limits, log the features and version behind every decision, and test for drift and bias. From 10 December 2026 your privacy policy must also describe how computer programs are used in decisions that significantly affect people.

Does responsible lending apply to small business loans?

The responsible lending obligations in the National Credit Act apply to regulated consumer credit, not to most lending to businesses. Small business borrowers can still complain to AFCA within its jurisdiction, and AFCA publishes a Lending to Small Business Approach describing what it expects. Your lawyers should map which products sit inside and outside the Code.

Which credit bureaus do Australian lenders connect to?

The main consumer bureaus are Equifax and Experian, and illion is now part of Experian. Lenders that participate in comprehensive credit reporting exchange repayment history information with bureaus under Part IIIA of the Privacy Act and the Credit Reporting Code, which brings strict rules on use, disclosure and correction.

Have you built lending software before?

No. AWLabs has not delivered a project for a lender, so we won't claim sector experience. We bring integration, data, rules engine and AI engineering. We hold no credit licence or AFSL, and we work to your credit, risk and compliance teams' requirements.

This page is general information about Australian law and regulation, current at the date shown. It is not legal advice. Get advice from a qualified lawyer about your circumstances.

Sources

  1. Responsible lending, ASIC
  2. RG 209 Credit licensing: Responsible lending conduct, ASIC
  3. Buy now pay later credit contracts: credit licensing, ASIC
  4. National Credit Code, ASIC
  5. Financial hardship, Moneysmart (ASIC)
  6. Hardship assistance and your credit report, OAIC
  7. About the AML/CTF reforms, AUSTRAC
  8. Privacy and Other Legislation Amendment Act 2024, Federal Register of Legislation
  9. AFCA's final Lending to Small Business Approach (archived copy), AFCA via Wayback Machine
  10. Helping your clients stay scam aware, MFAA
  11. illion is now part of Experian, Experian Australia
  12. Simpology mortgage origination platform, Simpology
  13. NextGen lending platform, NextGen
  14. Custom software development cost in Australia 2026, Expeed Software
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