HeroClear – TMD Determination For Non-Cash Payment Product
Target Market Determination For Non-Cash Payment Product
This TMD is prepared to meet Design and Distribution Obligations (Part 7.8A) of the Corporations Act 2001 (Cth). It is not a disclosure document or financial advice. Customers must read the HeroClear Terms and the Employment Hero Platform Terms and Conditions.
| Target Market Determination | |
| Product | HeroClear Non‑cash payment facility for superannuation contributions |
| Issuer | Employment Hero Pty Ltd (ABN 11 160 047 709) (Employment Hero, EH, we/us/our) |
| Start Date | March 2026 |
| Version | 2.0 – This TMD applies to HeroClear during General Availability. Date first made: 18112025 Initial review due: six months from first issue or at GA, whichever occurs first Last reviewed: March 2026 |
| Review Date | Every 12 months |
| Target market | This product is intended for Australian employer entities (with ABN/ACN) that: – use (or intend to use) the Employment Hero platform for payroll/HR; – seek to initiate superannuation contribution payments in batches and transmit SuperStream messages; – are able to confirm the debit amount and source account/channel for each Contribution Cycle; and – have operational capability to manage approvals, cut‑offs, reconciliation and error remediation. This product is not intended for: – individuals/consumers or non‑business users; – employers requiring financial product advice or guaranteed settlement times; – employers unable to maintain sufficient cleared funds, accurate data or timely approvals; – scenarios where EH is expected to act as a super fund, trustee, adviser or custodian. Having assessed the product’s attributes (next section), EH considers the product likely to be consistent with the possible objectives, financial situation and needs of the target market described above. |
| Product attributes | The product is a non‑cash payment facility issued by us, that lets you initiate payments for employer superannuation contributions and sends SuperStream messages to nominated funds. We create and manage PayTo mandates and BECS can be enabled as a fallback only if you’ve signed a DDRSA/DDR. Each Contribution Cycle requires you to confirm the total amount and source account/channel. We don’t use standing authorities. After confirmation, the platform initiates debits to fund the authorised batch of super contributions and we prepare and transmit SuperStream messages linked to the matching payment. Access can depend on the availability of the NPP/PayTo sponsor bank, BECS processor (if used), and messaging gateway; correct employer data; bank/fund cut‑offs. There are payment processing and messaging limitations: – Timing from debit to fund receipt is variable and contributions are treated as paid only on fund receipt; – During processing, funds may be held in an EH settlement account and EH retains interest on balances in transit; – External dependencies (banks, PayTo/BECS rails, SuperStream gateways) can affect availability and speed; and – Failed debits and data mismatches can trigger returns, requiring correction and resubmission. Fees are disclosed in-platform at enablement or provided by an Employment Hero representative, and may vary by plan, channel, cohort and other factors we communicate to customers. Third-party charges (e.g., dishonours/retries/returns) may be passed through. |
| Appropriate Statement | We have considered the product is likely to be consistent with the possible objectives, financial situation and needs of the Target Market because it enables integrated initiation of super contribution payments with linked SuperStream messaging, requires per-cycle approval, supports operational visibility and exception handling, and assumes access to a suitable Australian business bank account and tolerance for indicative (not guaranteed) settlement timing. |
| Distribution conditions & restrictions | The product is enabled only within the EH Platform. It may be distributed by Employment Hero and, where applicable, approved partners/resellers via in-platform enablement. Availability may be sequenced by cohort (including organisation size, complexity, region or channel) during controlled rollout. Access is limited to Australian employer entities with an ABN/ACN that accept the HeroClear Terms and General Terms and complete any required verification (including, KYB). Customers must maintain a supported Australian business bank account and, if they wish to use BECS, they must execute the DDRSA/DDR before it’s enabled. At the point of enablement and before each Contribution Cycle, the platform requires per-cycle confirmation of the total debit amount and the source account/channel, and it presents disclosures that contributions are only counted as paid when the destination fund receives them. The product is not distributed to individuals/consumers, it does not provide financial product advice, and it does not guarantee settlement times. |
| Review triggers & review periods | We will do an initial review of this TMD within six months of first issue (or earlier if a review trigger occurs), with periodic reviews at least every twelve months thereafter. We will otherwise review the TMD if any of the following triggers occur: – a material change to PayTo/NPP, BECS, or SuperStream rules or standards that affects product attributes; – a material change to the product’s design or key attributes, terms or conditions; – HeroClear is rolled out to new channels or materially broader cohorts (for example, distribution via approved partners/resellers or to significantly larger or more complex organisations) and that rollout could reasonably affect whether the product remains consistent with the Target Market; – enabling wage payments (or any other additional payment feature) for customers, or otherwise materially expanding HeroClear beyond superannuation contributions. For clarity, this TMD currently relates to HeroClear for superannuation contributions only and will be updated before wage payments are enabled; – any significant dealing that is not consistent with the target market or this TMD; or – material complaints (in number or significance) relate to complaints concerning the terms of this product and or the distribution conduct. |
| Reporting requirements (for distributors) | The distributor of the product must provide the following information to us, within the below timeframes: – a monthly complaints report within 10 business days of month-end; – any significant dealing outside the Target Market as soon as practicable and within 10 business days; – a monthly summary of payment failures, returns and SuperStream rejects by root cause; and – any out-of-market enablements within 5 business days of discovery. Distributors must escalate regulatory inquiries within 2 business days and send all reports in writing. Where we are the sole distributor, we will generate and retain these reports. |
| Record‑keeping & availability | – We will maintain records of this TMD, all reviews, distribution information, significant dealings and complaints per our retention policy. – We will publish the current TMD on our website and make it available in-platform. We will version-stamp the TMD and record key dates. – We will retain evidence of eligibility gates, point-of-sale controls and audit trails to demonstrate DDO compliance. Any distributor must keep equivalent records and provide them to us on request. |


















