Comprehensive Credit Reporting: are the reforms as positive as promised?

By Jennifer La'au and Damian Kelly

Key takeaways

• The Financial Institutions (Amendment) Act 2025 (Reform) shifts Vanuatu from a negative‑only credit reporting system to a comprehensive regime recognising positive repayment behaviour.

• A centralised, RBV‑regulated credit bureau will introduce mandatory reporting, six‑year data‑retention rules, and stronger privacy protections.

• Operational uncertainties remain due to the absence of RBV guidance, creating challenges for institutions needing system upgrades and clearer reporting standards.

At a glance

On 22 December 2025, the Financial Institutions (Amendment) Act 2025 (Reform) was gazetted into law, empowering the Reserve Bank of Vanuatu (RBV) the power to establish and maintain a comprehensive credit reporting regime. The explanatory note that was annexed as a foreword to the Reform before it was passed by Parliament last year described the new law as creating “visibility of borrowers’ positive repayment behaviour.” However, a month on from its enactment, the RBV has yet to provide guidance on how the Reform will be rolled out, raising the question on whether positive credit reporting will become a reality?

Current credit report

Currently, the Data Bureau (Vanuatu) Limited, a private company, operated on behalf of its members provides the only credit reporting service in Vanuatu. The Data Bureau’s current members including the following financial institutions ANZ, Banyan Financial Group, Bred, BSP, Credit Corporation and NBV.

Data Bureau operates on a voluntary code of conduct, meaning the rules applied to it have no regulatory or governmental oversight. This means that repayment behaviour tracking is primarily focussed on negative reporting driven by the Data Bureau’s members and complaints by individuals and businesses affected by negative credit reports are dealt with internally. Meaning, where there is a mistake or a person is adversely affected by a negative credit report, there is little recourse.

The reforms

The amendments address the limitations of the current "negative-only" credit reporting model by recognising positive repayment behaviour, thereby promoting financial inclusion and improving access to credit for underserved individuals and communities.

The Act mandates the establishment of a centralised credit bureau to ensure data accuracy and consistency, with data retention limited to six years, after which it must be securely destroyed. The RBV is authorised to issue directives requiring licensees and credit institutions to report prescribed data types, including but not limited to account balances, debt ratios, on-time payments, credit limits, and public record data, among others. These measures aim to enhance RBV's oversight capabilities, mitigate systemic risks, and promote responsible lending practices.

The reforms also introduce rules around record retention and privacy, requiring for information to be maintained for six years and then subsequently destroyed in a secure fashion. Such changes will ensure that a clear record is maintained so that any complaints can be reviewed and hopefully resolved, while also creating a time limit on the use of data ensuring that borrowers are not adversely affected by negative behaviour after significant time has elapsed.

The Government of Vanuatu says that the reforms will align Vanuatu's credit reporting framework with international best practices, such as those endorsed by the World Bank, and strengthen financial integrity by enabling data-driven regulation and evidence-based policymaking.

How will the reforms operate?

The RBV is yet to publish official guidance or regulations so how the Reform will operate is not clear. Some risks arise from the lack of regulatory clarification, including:

• The scope of prescribed data types that must be submitted for the purpose of reporting is open ended and so there is ambiguity to the limit of the RBV’s authority and the role of the credit bureau;

• Financial institutions that have operated credit reporting on a voluntary basis may find it difficult to upgrade their processes to ensure compliance with the new comprehensive reporting requirements;

• The requirement to report extensive data types (account balances, payment patterns, assets and liabilities, etc.) may pose operational challenges in terms of capturing, validating, and transmitting such information. Differences in record-keeping standards across institutions could result in incomplete or non-uniform data, undermining the reliability of the centralised credit bureau; and

• Centralising all credit data in a single bureau increases the risk that systemic failure, security breach, or operational disruption at the credit bureau could have widespread impact across the entire financial sector. 

Next steps

At this stage there is a bit of a waiting game until regulatory guidance is provided. To ensure an effective transition to comprehensive credit reporting, the RBV must issue clear regulations detailing data‑submission requirements, reporting timelines, and operational standards for the centralised credit bureau. Financial institutions should assess system readiness, upgrade data‑capture processes, and strengthen privacy and cybersecurity frameworks to meet the new obligations. Coordination between the RBV, industry, and consumer groups will be essential to resolve uncertainties and support practical implementation. Public education will also hopefully play a key role in helping borrowers understand how positive reporting affects their credit standing.

Need help?

If you would like advice on how the Financial Institutions (Amendment) Act 2025 may affect your organisation, contact our team for tailored guidance and compliance support.