New rules bringing Buy Now Pay Later (BNPL) providers within the Financial Conduct Authority’s (FCA) regulatory remit came into force on 15 July 2026.

The change follows a Government consultation in late 2024 (discussed here) which set out its intention to amend the position at the time which saw so-called ‘deferred payment credit’ (DPC) contracts enjoy an exemption from consumer credit regulation. Describing the need to “act with urgency to deliver regulation”, the Government proposed measures to “bring into regulation DPC agreements where they are offered by a third-party lender”.

These proposals were implemented last year by the Financial Services and Markets Act 2000 (Regulated Activities etc.) (Amendment) Order 2025, which came into force on 15 July 2026. Under the new rules, any lender offering DPC agreements must both (1) be authorised for the relevant consumer credit activities or have a temporary permission under the DPC temporary permissions regime and (2) comply with the FCA’s regulatory rules.

In a press release from earlier this year (here), the FCA set out what the new changes will mean in practice for providers of BNPL products, pointing to the fact that they will now be subject to the FCA’s Consumer Duty such that consumers will benefit from:

• Clear information. Consumers must be given clear, upfront details about their agreement, including when payments will be due, amounts, and what happens if they miss a payment.
• Affordability checks. Lenders must carry out proportionate checks to make sure customers can afford to repay what they borrow before offering BNPL products.
• Support when needed. Lenders will need to offer support to customers in financial difficulty, and, where appropriate, direct them to free debt advice.
• Complaints and compensation. If something goes wrong, consumers will be able to complain to the Financial Ombudsman Service.

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