GET AUTHORISED
Regulated since 15 July 2026 · Apply for full authorisation by January 2027Perimeter, permissions and customer controls for regulated Deferred Payment Credit.
Deferred Payment Credit is now regulated and the Temporary Permissions Regime is closed to new entrants. Firms on temporary permission must apply for full authorisation 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.
SERVICE OVERVIEW
Understand how the regulated Deferred Payment Credit regime applies to the BNPL model.
BNPL providers, lenders, merchants and firms in a deferred-payment distribution chain. A clear assessment of regulated lending, exclusions, permissions and practical compliance actions.
Ready to submit within 6 weeks, often sooner
Under FSMA the FCA must decide within 6 months of receiving a complete application, or within 12 months of receiving an incomplete one.
Where the regime stands
Deferred Payment Credit lending by third-party lenders has been regulated since 15 July 2026. Firms that notified into the temporary permissions regime must apply for full authorisation within the six-month window that closes in January 2027.
Start with the part of the BNPL model that is changing or uncertain.
Perimeter
Separate regulated third-party lending from exclusions.
Permissions
Plan the route and responsible ownership.
Customer journey
Review affordability, disclosures and support.
Implementation
Turn requirements into controls and evidence.
From model analysis to operational readiness
The regime is live: the work is establishing where the firm sits against the Deferred Payment Credit perimeter, then building and evidencing what a lending permission requires.
What the FCA expects, and the evidence behind it.
Model perimeter
Understand product structure, parties and regulated activity.
Permissions strategy
Set a realistic route for the business and timeline.
Customer outcomes
Review conduct, affordability and support controls.
Governance
Create accountable implementation ownership.
BNPL readiness depends on how the provider, lender, merchant and customer interact.
The readiness plan should show how good outcomes will be managed across the chain.
Where the Deferred Payment Credit regime now stands
Deadline to Apply for Full Authorisation
Deferred Payment Credit became regulated on 15 July 2026 and the Temporary Permissions Regime is closed to new entrants. Firms holding temporary permission must apply for full authorisation by January 2027.
In Scope
Interest free credit products repayable in twelve or fewer instalments within twelve months, where the lender finances purchases from a merchant.
Outside Scope
Merchant provided own credit remains outside the new perimeter. Structuring analysis is critical to determine where the regulated risk sits.
But Conduct Questions Remain
The legislation keeps the broking of Deferred Payment Credit agreements outside regulation, though wider governance questions can remain relevant.
Firms that treat this as a narrow classification exercise often discover the real challenge is reshaping the operating model in time.
We help clients answer the commercial questions that sit behind the regulation
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.
Firms preparing for BNPL regulation may also need
Deeper reading on the regulatory framework relevant to BNPL providers.
End-to-end support across the full regulatory lifecycle.
Select a question to view the answer.
Yes. Deferred Payment Credit came under FCA regulation on 15 July 2026. The Temporary Permissions Regime is closed to new entrants, and firms in it must apply for full authorisation by January 2027.
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.
The legislation keeps the broking of Deferred Payment Credit agreements outside regulation. Even so, firms should still analyse their role carefully because wider conduct, distribution, and governance questions can remain highly relevant.
It depends where you stand. Firms on temporary permission should be building the full authorisation application now, because January 2027 is the last date in the window to apply for full authorisation. Firms carrying on regulated Deferred Payment Credit activity since 15 July 2026 without authorisation or temporary permission 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.
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.
Prefer to talk it through first? Call and you will speak to a consultant, not a switchboard.
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