When does BNPL regulation start in the UK?

The FCA has confirmed that regulation of Deferred Payment Credit will begin on 15 July 2026.

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?

They should be analysing whether the model is in scope, assessing permissions implications, reviewing customer journeys, and beginning the implementation work needed across controls, governance, disclosures, support processes, and monitoring.

Regulation Starts 15 July 2026

BNPL Regulation Support

The UK regime for Deferred Payment Credit is now settled in principle and moving towards implementation. MEMA helps firms prepare with perimeter analysis, permissions strategy, customer journey review, governance, and the practical decisions needed before regulation day.

Assess Your Position Call: 0330 133 0811

The Regulatory Position

Key facts about the incoming Deferred Payment Credit regime

15 July 2026

Regulation Start Date

The FCA has confirmed that Deferred Payment Credit regulation will begin on this date. Temporary permissions notifications open from 15 May 2026.

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
Temporary permissions regime eligibility
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

Prepare Before the Window Closes

If your business is exposed to BNPL reform, the right time to structure the response is before the implementation window becomes compressed.

Phone: 0330 133 0811

Email: contact@memaconsultants.com