Insights ¦ Consultation Paper CP25/23*** Deferred Payment Credit (unregulated Buy Now Pay Later): Proposed approach to regulation

Published by: Financial Conduct Authority
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Key Take Aways

The FCA is establishing a proportionate regulatory framework for Deferred Payment Credit (DPC), currently known as Buy Now Pay Later (BNPL), bringing it into the FCA’s regulatory perimeter from July 2026.
The regime relies on expanding existing high-level standards, including the Consumer Duty, alongside bespoke rules to address current gaps posed by legislation and market practices.
A core focus is providing consumers with clear, timely, and effective information before, during, and after a DPC agreement to support informed decision-making and responsible borrowing.
FCA proposes to apply existing rules on creditworthiness, mandating proportionate assessments to safeguard consumers from unaffordable lending, especially those exhibiting characteristics of vulnerability.
Dispute resolution will be reinforced, with FCA rules extending to complaints handling and referrals to the Financial Ombudsman Ser...

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