Regulated since 15 July 2026 · Full authorisation due January 2027

BNPL Regulation Support

Deferred Payment Credit is now regulated and the Temporary Permissions Regime has closed. Firms on temporary permission must be fully authorised by January 2027. If you did not register in time, that position can still be put right, and the sooner it is looked at the more options remain. MEMA helps with authorisation applications, perimeter analysis, customer journey review, governance, and firms outside the temporary regime.

Assess Your PositionCall: 0330 133 0811

The Buy Now Pay Later Regulation journey

The route from scoping your permissions to a decision. The FCA's part of it is fixed; the preparation before it is where applications are won or lost.

Establish where your agreements sit

How your deferred payment credit is structured, and where that leaves you against the perimeter and the temporary permissions position as it stands.

  • Analyse the agreement structure and the credit provided
  • Confirm your permission or temporary permission status
  • Establish the position if the registration window was missed
What applies
Buy now pay later lending
Where it sits in the rules
CONC, deferred payment credit
FCA determination
6–12 months

Statutory period from a complete application

FCA application fee
£280

Temporary permission notification. No full-authorisation fee is published yet

What needs clarifying?

Start with the part of the BNPL model that is changing or uncertain.

Perimeter

Separate regulated third-party lending from exclusions.

Key Buy Now Pay Later Regulation Requirements

What the FCA expects, and the evidence behind it.

Model perimeterUnderstand product structure, parties and regulated activity.
Permissions strategySet a realistic route for the business and timeline.
Customer outcomesReview conduct, affordability and support controls.
GovernanceCreate accountable implementation ownership.

What you will need to produce

  • Model and perimeter analysis
  • Permissions strategy
  • Customer journey and conduct review
  • Implementation roadmap and control evidence

Start with the product chain

BNPL readiness depends on how the provider, lender, merchant and customer interact.

Parties and contracts

Map who provides credit, makes decisions, receives fees and communicates with the customer.

Customer journey

Review application, affordability, disclosures, repayment, support and collections.

Perimeter decision

Separate the activity analysis from assumptions about future regulation or product labels.

Prepare practical customer controls

The readiness plan should show how good outcomes will be managed across the chain.

Affordability and support

Assess creditworthiness, customers in difficulty, vulnerability and escalation.

Governance

Set ownership for product, conduct, merchant and lender oversight.

Implementation roadmap

Create actions, owners and evidence for permissions, controls, communications and monitoring.

How MEMA helps

The work here is preparation under a moving target: establishing where the firm sits, then building what will be needed without over-building for rules that are not final.

  1. 01

    Analyse the model

    We establish precisely how your agreements are structured and where they sit against the perimeter as it stands.

  2. 02

    Set the permissions strategy

    A decision on what to apply for and when, with the reasoning recorded so it can be revisited as the position develops.

  3. 03

    Review the customer journey

    The journey is assessed end to end — disclosure, affordability, arrears and forbearance — because that is what conduct expectations attach to.

  4. 04

    Build the control framework

    Policies, governance and monitoring built to the standard a lending permission requires, sequenced so nothing is wasted if the detail shifts.

  5. 05

    Run the roadmap

    An implementation plan with owners and checkpoints, updated as the regime is finalised rather than rewritten.

The areas we cover

From model analysis to operational readiness

  • Model Analysis

    • Legal structure and lending relationship
    • Role of merchants and platforms
    • Customer journey mapping
    • Allocation of responsibilities

  • Permissions Strategy

    • Scope assessment and perimeter analysis
    • Permissions route evaluation
    • Full authorisation applications for firms on temporary permission
    • Commercially sensible route selection

  • Operational Build

    • Customer communications and disclosures
    • Affordability and complaints handling
    • Consumer Duty alignment
    • Governance, MI, and implementation planning

The Regulatory Position

Where the Deferred Payment Credit regime now stands

January 2027

Full Authorisation Deadline

Deferred Payment Credit became regulated on 15 July 2026 and the Temporary Permissions Regime has closed. Firms holding temporary permission must complete full authorisation by January 2027.

Third Party Lender Models

In Scope

Interest free credit products repayable in twelve or fewer instalments within twelve months, where the lender finances purchases from a merchant.

Merchant Own Credit

Outside Scope

Merchant provided own credit remains outside the new perimeter. Structuring analysis is critical to determine where the regulated risk sits.

Broking Remains Exempt

But Conduct Questions Remain

The FCA has confirmed that broking of Deferred Payment Credit agreements will remain exempt, though wider governance questions can remain relevant.

BNPL Reform Is an Operational Challenge, Not Just a Legal One

Firms that treat this as a narrow classification exercise often discover the real challenge is reshaping the operating model in time.

Which entity carries the regulated risk
Where customer harm could arise
How affordability expectations will be met
What changes are needed across onboarding and checkout
How complaints and governance must evolve
Whether disclosures and monitoring are adequate

What Makes MEMA Different

We help clients answer the commercial questions that sit behind the regulation

Is the current structure still workable?
Does the permissions strategy make sense?
Is the customer journey defensible?
Have governance and oversight caught up with the risk?
Is the business actually building something ready for regulation?
Will the proposition stand up in a more regulated environment?

Related Services

Firms preparing for BNPL regulation may also need

Consumer CreditFCA AuthorisationConsumer DutyCredit BrokingConsumer Credit Sector

Related FCA Guidance

Deeper reading on the regulatory framework relevant to BNPL providers.

Handbook

CONC: Consumer Credit Sourcebook

The FCA rules that govern regulated BNPL products, including Deferred Payment Credit.

Sector

Consumer Credit Affordability

Affordability assessments BNPL providers are required to conduct.

Handbook

PERG: Perimeter Guidance

Understanding where BNPL sits within the evolving regulatory perimeter.

Speak to a specialist

Talk to us about your BNPL position

Whether you are building a full authorisation application, still assessing scope, or dealing with a missed TPR window, tell us where you stand and we will come back to you.

0330 133 0811

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Frequently Asked Questions

Select a question to view the answer.

Is BNPL now regulated in the UK?

Yes. Deferred Payment Credit came under FCA regulation on 15 July 2026. The Temporary Permissions Regime registration window has closed, and firms holding temporary permission must secure full authorisation by January 2027.

Will all BNPL models be regulated?

No. The perimeter is more specific than that. The new regime focuses on Deferred Payment Credit provided by third party lenders financing goods or services from merchants. Merchant own credit remains outside scope, so structuring analysis matters.

Will brokers need to be regulated under the new regime?

The FCA has confirmed that the broking of Deferred Payment Credit agreements will remain exempt. Even so, firms should still analyse their role carefully because wider conduct, distribution, and governance questions can remain highly relevant.

What should firms be doing now?

It depends where you stand. Firms on temporary permission should be building the full authorisation application now, because the January 2027 deadline governs a queue, not a submission date. Firms that did not register during the TPR window and are carrying on regulated Deferred Payment Credit activity are operating without permission and need urgent advice on their position. Firms still unsure whether they are in scope should start with a perimeter analysis.