Target Market Determination

Introduction

Paid Transaction Account

Issuer: Paid Dot Pty Ltd (ABN 14 642 944 278)

AFSL No: 700215

Effective Date: 23/02/2026

Version: 2.0

1. Purpose

This Target Market Determination (TMD) is made pursuant to Part 7.8A of the Corporations Act 2001 (Cth).

It describes the class of consumers for whom the Paid Transaction Account is likely to be consistent with their likely objectives, financial situation and needs, and sets out distribution conditions and review triggers.

This TMD does not form part of the terms and conditions of the product.

2. Product Description

The Paid Transaction Account is a Non-Cash Payment (NCP) facility that enables users to deposit, hold and transfer funds electronically in connection with construction, property-related and business service based contracts.

Funds are held in accordance with client money obligations under the Corporations Act. The facility is designed for project-linked payment administration and is not intended to function as a savings, investment or deposit product.

The product does not provide credit. The product does not provide investment returns.

3. Target Market

3.1 Consumers for whom the product is likely to be appropriate

The product is likely to be appropriate for consumers who:

• Are individuals aged 18 years or over, or incorporated entities
  
• Are participating in a construction, property development or related professional services transaction
  
• Require a structured electronic payment facility linked to a specific contract or project
  
• Seek conditional or milestone-based disbursement and automation of funds
  
• Require auditability and controlled payment workflows
  
• Do not require interest or capital growth on deposited funds

This includes:

Retail Consumers

• Residential property owners engaging builders or contractors
  
• Residential property owners or purchasers engaging the transaction of a property
  
• Individuals requiring conditional project-based disbursement of funds

Likely objectives:

• To reduce payment risk
  
• To align disbursements with contractual milestones
  
• To obtain transparency over fund movements
  

Business and Wholesale Consumers

• Licensed builders and contractors managing subcontractor payments
  
• Developers and funders seeking structured project payment oversight
  
• Professional advisors administering project funds

Likely objectives:

• Automated or rule-based payment processing
  
• Reconciliation and reporting of project payments
  
• Contract-linked fund control

4. Negative Target Market

The product is not likely to be appropriate for consumers who:

• Are seeking a deposit account, savings account or capital-protected investment
  
• Are seeking interest or yield on deposited funds
  
• Require general transactional banking facilities (e.g., debit cards, ATM withdrawals)
  
• Intend to use the facility for general-purpose or non-project-related transactions
  
• Are seeking speculative or investment exposure

5. Key Product Attributes

The following attributes are relevant to determining appropriateness:

• Funds are held in accordance with client money requirements under the Corporations Act.
  
• The facility supports electronic transfers via Australian payment systems.
  
• Accounts must be linked to a verified project or contractual arrangement.
  
• Any interest earned on pooled client money accounts may be retained by the issuer to cover operational expenses relating to the product, as permitted under applicable law and disclosed in product documentation.
  
• The product does not provide capital growth or investment management.

These attributes are consistent with the likely objectives and needs of the target market identified above.

6. Distribution Conditions

To ensure distribution is reasonably likely to result in consumers within the target market acquiring the product, the following conditions apply:

• Accounts may only be opened following completion of identity verification (KYC/KYB).
  
• Accounts must be linked to a verified project or contractual relationship.
  
• Marketing materials must not describe the product as an investment, savings or interest-bearing account.
  
• Distribution is limited to:
  
  • Direct onboarding through Paid’s controlled digital platform
    
  • Approved integration partners operating within construction, property or service based business sectors
    

Mass-market advertising to general retail savers is not permitted.

7. Review Triggers

This TMD will be reviewed within 10 business days if any of the following occurs:

• A material increase in complaints relating to product suitability
  
• More than 5 substantiated complaints in a calendar month relating to any misunderstanding of funds
  
• Identification of a significant dealing outside the target market
  
• Evidence of systematic non-project-related use of accounts
  
• A material change to product design or fund handling arrangements
  
• ASIC guidance, regulatory action, or stop order relevant to NCP facilities or client money arrangements

In any event, this TMD will be reviewed at least annually.

8. Reporting Obligations Of Distributors

Distributors must provide:

• Quarterly complaint data
  
• Notification within 10 business days of becoming aware of a significant dealing inconsistent with this TMD
  
• Any material information that may reasonably suggest the TMD is no longer appropriate