FCA Regulatory Update: PS26/1: Regulation of Deferred Payment Credit (unregulated Buy Now Pay Later)

The Hook

PS26/1: Regulation of Deferred Payment Credit (unregulated Buy Now Pay Later) is now regulated - firms that have not updated their policies and controls face enforcement risk from day one. This is one of 5 FCA publications this week spanning PS26/1, CP26/1, CP25/30, CP26/7, CP25/2 that compliance teams need to act on. Relevant handbook areas include: COBS 9A.2.1R (Suitability requirement): Requires firms to gather sufficient client information and test suitability when giving personal recommendations to retail clients.

Top source items by relative impact score for this briefing.

Source update	Impact score	Priority
PS26/1: Regulation of Deferred Payment Credit (unregulated Buy Now ...	95	High
CP26/1: The Value for Money Framework: Response to consultation, fu...	90	High
CP25/30: Streamlining the UK EMIR Intragroup Regime	90	High
CP26/7: Credit Information Market Study: Proposed approach to imple...	88	High
CP25/2: Proposed changes to MiFID conduct of business rules for ret...	85	High

Use this table to prioritise ownership and implementation sequencing.

This Week's Developments

PS26/1: Regulation of Deferred Payment Credit (unregulated Buy Now Pay Later)

The regulation of Deferred Payment Credit (DPC) will ensure that DPC borrowers have appropriate protections when using the product. This shifts from consultation to enforcement - the FCA will now assess compliance against these standards, not against good intentions. Firms should run a gap analysis against the specific requirements, assign an accountable owner for each control change, and build an evidence pack before the next supervisory engagement.

CP26/1: The Value for Money Framework: Response to consultation, further consultation and discussion paper

The Value for Money (VFM) Framework is intended to support a significant shift in the way the workplace pensions industry operates and competes. The practical question for firms is not whether to act but how quickly to move. Impact assessments should start now because waiting for final rules compresses implementation into a window that leaves no room for testing or training.

CP25/30: Streamlining the UK EMIR Intragroup Regime

This would make the UK EMIR Intragroup Regime clearer for counterparties seeking intragroup exemptions from clearing and margin requirements. The level of detail in this consultation suggests the FCA has already made its policy decision - the question period is about calibration, not direction. Firms that treat this as theoretical will find themselves scrambling once final rules confirm what is already clear. The original FCA deadline of 2026-01-16 has already passed - firms that have not yet acted should treat this as an immediate priority.

CP26/7: Credit Information Market Study: Proposed approach to implementing FCA remedies

This would improve how consumer credit information is shared and used across retail lending markets. What matters here is the cumulative burden: this consultation, combined with recent FCA output in the same area, points to a higher bar for evidenced compliance. Firms need to assess whether their current controls can meet the expected standard. The FCA deadline is 2026-05-01 and firms should plan their response well ahead of this date.

CP25/2: Proposed changes to MiFID conduct of business rules for retail investors

Amendments to COBS to strengthen protections for retail investors accessing complex investment products. Firms affected by these proposals should map them against existing processes and identify gaps before the consultation closes. Early responders will also shape the final rules - silence is not a neutral position.

What Firms Should Do

The Bigger Picture

5 of this week's publications touching Vulnerable Customers, Technology & Data, AML & Financial Crime point in the same direction - the FCA is raising the bar on policy implementation standards. Firms should read this as a pattern, not a series of isolated updates, and align their governance response accordingly.

Source Evidence