Zip Co Limited (ZIP.AX): Follow-up on NY BNPL regulations

Research evidence excerpt

Zip Co Limited (ZIP.AX): Follow-up on NY BNPL regulations

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20 Jul 2026 02:24:59 ET │ 11 pages

Zip Co Limited (ZIP.AX)

Follow-up on NY BNPL regulations

CITI'S TAKE

Buy NY's DFS has formally published proposed rule changes for BNPL

providers in the state after announcing proposed changes earlier this year. Price (20 Jul 26 13:14) A$2.90

As per the new definitions, Zip would be considered a BNPL lender and Target price A$3.55

would need to be licensed in the state but more importantly this could cap Expected share price return 22.4%

the fees that Zip could charge. While NYC itself is likely not material in Expected dividend yield 0.0%

terms of volumes, the question is whether this becomes the norm for Expected total return 22.4%

other states as well.

Market Cap A$3,613M

US$2,534M

• Zip would be considered a BNPL lender: While ZIp technically uses

Webbank to offer its BNPL loans , under NY's proposed BNPL regulation, Siraj AhmedAC

Zip would be considered the BNPL lender as the BNPL loan ownership is +61-3-8643-9781

transferred to it after the initial purchase. Also, the changes does siraj.ahmed@citi.com

specifically mention companies that operate a platform, software or system

Howard Suen

that consumers interact with as a BNPL lender.

howard.suen@citi.com

• Interest charges definition is quite broad and unsure if Federal Charter

can override NY state BNPL requirements : The definition for Interest

revenue includes installment fees, payment delay fees. etc. Importantly, the

changes include capping the interest on any BNPL loan to not be higher

than what is permitted by permitted by General Obligations Law section 5-

501 - our understanding is that this limits interest rates to 16% and given

Zip would be regulated as a BNPL lender it is unclear whether Zip can use