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

Executive Summary

This week's key FCA publication — PS26/1: Regulation of Deferred Payment Credit (unregulated Buy Now Pay Later) — Our final rules on the regulation of Deferred Payment Credit (DPC) will ensure that DPC borrowers have appropriate protections when using the product. ... Read PS26/1 (PDF)What we are changing DPC has been more commonly known as Buy Now Pay Later (BNPL).DPC refers to an interest-free credit product,

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.

Firms should treat this as a board-sponsored delivery programme with named owners, evidence standards, and timeline checkpoints. 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..

Regulatory Signal: What Changed This Week

• PS26/1: PS26/1: Regulation of Deferred Payment Credit (unregulated Buy Now Pay Later) — Our final rules on the regulation of Deferred Payment Credit (DPC) will ensure that DPC borrowers have appropriate protections when using the product. ... Read PS26/1 (PDF)What we
• CP26/1: 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. This document c...
• CP25/30: CP25/30: Streamlining the UK EMIR Intragroup Regime — Read our proposals to make the UK EMIR Intragroup Regime clearer for counterparties seeking intragroup exemptions from clearing and margin requirements. ... Read CP25/30Why we are
• CP26/7: CP26/7: Credit Information Market Study: Proposed approach to implementing FCA remedies — We are consulting on proposals designed to improve how consumer credit information is shared and used across retail lending markets. ... Read CP26/7 (PDF)Why we are consultingOur p
• CP25/2: CP25/2: Proposed changes to MiFID conduct of business rules for retail investors — The FCA is consulting on amendments to COBS to strengthen protections for retail investors accessing complex investment products. The proposals include enhanced disclosure requirem

Exposure: Which Firms and Functions Are Most Affected

• Firms operating in Consumer Credit sectors with active regulatory obligations.
• Teams where compliance interpretation, legal wording, and operations rollout are not yet aligned.
• Boards without a current evidence-backed view of remediation progress and residual risk.

Priority Actions (Next 30/60/90 Days)

Action	Owner	Deadline	Evidence	Client impact	Source ref
Update internal policies and procedures to reflect requirements in PS26/1: Regulation of Deferred Payment Credit (unregulated Buy Now Pay Later).	Compliance Lead	No FCA deadline — recommend internal 60-day implementation target	Updated policy documents, gap analysis, and implementation plan with owner sign-off.	Ensures firm meets new rule requirements; prevents enforcement risk.	PS26/1
Review CP26/1: The Value for Money Framework: Response to consultation, further consultation and discussion paper and submit consultation response before the closing date.	Head of Compliance	No FCA deadline — recommend internal 60-day implementation target	Consultation response document with internal sign-off and board awareness.	Shapes final rules in firm's favour; early response signals supervisory engagement.	CP26/1
Review CP25/30: Streamlining the UK EMIR Intragroup Regime and submit consultation response by 2026-01-16.	Head of Compliance	2026-01-16	Consultation response document with internal sign-off and board awareness.	Shapes final rules in firm's favour; early response signals supervisory engagement.	CP25/30
Review CP26/7: Credit Information Market Study: Proposed approach to implementing FCA remedies and submit consultation response by 2026-05-01.	Head of Compliance	2026-05-01	Consultation response document with internal sign-off and board awareness.	Shapes final rules in firm's favour; early response signals supervisory engagement.	CP26/7
Review CP25/2: Proposed changes to MiFID conduct of business rules for retail investors and submit consultation response before the closing date.	Head of Compliance	No FCA deadline — recommend internal 60-day implementation target	Consultation response document with internal sign-off and board awareness.	Shapes final rules in firm's favour; early response signals supervisory engagement.	CP25/2

Board Decisions Required This Month

1. Approve implementation approach for PS26/1: Regulation of Deferred Payment Credit (unregulated Buy Now Pay Later) (PS26/1) — confirm resource allocation, risk appetite, and delivery timeline.
2. Approve implementation approach for CP26/1: The Value for Money Framework: Response to consultation, further consultation and discuss... (CP26/1) — confirm resource allocation, risk appetite, and delivery timeline.
3. Approve implementation approach for CP25/30: Streamlining the UK EMIR Intragroup Regime (CP25/30) — confirm resource allocation, risk appetite, and delivery timeline.
4. Approve implementation approach for CP26/7: Credit Information Market Study: Proposed approach to implementing FCA remedies (CP26/7) — confirm resource allocation, risk appetite, and delivery timeline.

Client Communication Guidance

• Use approved wording linked to implemented controls; avoid promises ahead of tested delivery.
• State what has changed in relation to PS26/1: Regulation of Deferred Payment Credit (unregulated Buy Now Pay Later), what clients should expect next, and expected completion windows.
• Maintain one accountable owner for outbound messaging consistency.

Source Evidence

Source	Document type	Published	Why it matters
PS26/1: Regulation of Deferred Payment Credit (unregulated Buy Now Pay Later)	PS (PS26/1)	2026-02-11	Our final rules on the regulation of Deferred Payment Credit (DPC) will ensure that DPC borrowers have appropriate protections when using the product. ... Read PS26/1 (PDF)What we are changing DPC has been more common...
CP26/1: The Value for Money Framework: Response to consultation, further consultation and discussion paper	CP (CP26/1)	2026-01-08	The Value for Money (VFM) Framework is intended to support a significant shift in the way the workplace pensions industry operates and competes. This document contains our updated proposals, reflecting feedback from t...
CP25/30: Streamlining the UK EMIR Intragroup Regime	CP (CP25/30)	2025-11-05	Read our proposals to make the UK EMIR Intragroup Regime clearer for counterparties seeking intragroup exemptions from clearing and margin requirements. ... Read CP25/30Why we are consultingThe Temporary Intragroup Ex...
CP26/7: Credit Information Market Study: Proposed approach to implementing FCA remedies	CP (CP26/7)	2026-02-25	We are consulting on proposals designed to improve how consumer credit information is shared and used across retail lending markets. ... Read CP26/7 (PDF)Why we are consultingOur proposals include a mandatory reportin...
CP25/2: Proposed changes to MiFID conduct of business rules for retail investors	CP (CP25/2)	2025-10-14	The FCA is consulting on amendments to COBS to strengthen protections for retail investors accessing complex investment products. The proposals include enhanced disclosure requirements for ESG-labeled funds and strict...