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.

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, and firms that missed the window are carrying on regulated activity without permission. MEMA helps with authorisation applications, perimeter analysis, customer journey review, governance, and resolving an unpermissioned position.

Assess Your Position Call: 0330 133 0811

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

How MEMA Helps

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

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?

Frequently Asked Questions

Select a question to view the answer.

Related Services

Firms preparing for BNPL regulation may also need

Consumer Credit FCA Authorisation Consumer Duty Credit Broking Consumer 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

Prefer to talk it through first? Call and you will speak to a consultant, not a switchboard.

Full Authorisation Is Due by January 2027

Temporary permission is not a destination. If you are on the TPR, or missed it and are still trading, the position needs resolving now rather than close to the deadline.

Phone: 0330 133 0811

Email: contact@memaconsultants.com