Buy Now Pay Later (BNPL) Compliance Check

From 15 July 2026, Deferred Payment Credit (DPC) — commonly known as Buy Now Pay Later — comes within the UK regulatory perimeter for the first time, under the Financial Conduct Authority’s final rules published in Policy Statement PS26/1 on 11 February 2026. Any business that offers BNPL at checkout, whether through Klarna, Clearpay, PayPal Pay in 3, or another provider, needs to check its arrangements now. Lenders offering DPC must hold FCA authorisation or have registered for the Temporary Permissions Regime between 15 May and 1 July 2026, after which they have six months to secure full authorisation. Retailers are not automatically off the hook: if you introduce customers to a BNPL lender at checkout, you may be acting as a credit broker, and your merchant agreement, checkout messaging, and any financial promotions referencing “pay in 3” or “spread the cost” now fall under FCA financial promotion rules.

The new regime brings mandatory affordability checks, clearer pre-contract information, a right for customers to complain to the Financial Ombudsman Service, and Consumer Duty obligations on lenders — all of which change the checkout experience and dispute-handling process for any merchant offering BNPL. Businesses that continue promoting or facilitating BNPL through a provider that hasn’t secured temporary or full FCA permission risk promoting unauthorised credit, a criminal offence under the Financial Services and Markets Act 2000. With the go-live date now days away, any business offering deferred payment options at checkout should confirm its provider’s regulatory status and review its own checkout and marketing materials before 15 July.

This check reviews your Buy Now Pay Later arrangements ahead of the FCA’s 15 July 2026 regulation of Deferred Payment Credit — covering provider authorisation, merchant agreements, financial promotions, and credit broking risk.