News & Analysis as of

Buy Now Pay Later (BNPL) Financial Conduct Authority (FCA)

Mayer Brown

Securitisation Regulatory Update: UK Regulator Consults on Reforms to Deferred Payment Credit (Buy Now Pay Later)

Mayer Brown on

On 14 July 2025, the FSMA (Regulated Activities etc) (Amendment) Order 2025 (the "DPC Legislation") brought unregulated deferred payment credit ("DPC") within the UK Financial Conduct Authority's ("FCA") remit. According to...more

A&O Shearman

UK FCA consults on BNPL rules for 15 July 2026

A&O Shearman on

The UK Financial Conduct Authority (FCA) has published consultation paper CP25/23, alongside a press release and new webpage, setting out its proposed rules for regulating Deferred Payment Credit (DPC), commonly known as Buy...more

A&O Shearman

UK CBA Panel issues statement on FCA's consultation paper on regulating BNPL products

A&O Shearman on

The Cost Benefit Analysis (CBA) Panel has issued a statement in response to the UK Financial Conduct Authority's (FCA) consultation paper on proposed rules to regulate Deferred Payment Credit (DPC) products, commonly known as...more

Skadden, Arps, Slate, Meagher & Flom LLP

FCA Publishes New Proposals for Buy Now, Pay Later Regulation: One-Year Countdown to July 2026 Implementation

- What is new: The FCA has published Consultation Paper 25/23 proposing new regulations for Buy Now, Pay Later (BNPL) services, now termed deferred-payment credit (DPC), with rules coming into force on 15 July 2026. - Why it...more

A&O Shearman

The continuing journey towards buy now, pay later regulation

A&O Shearman on

One could be forgiven, amidst the noise and glamour of the Leeds Reforms and the Mansion House speech, for having missed the snappily titled Financial Services and Markets Act 2000 (Regulated Activities etc.) (Amendment)...more

Hogan Lovells

BNPL: Buy Now, Regulate in 2026 - FCA publishes proposals

Hogan Lovells on

Key takeaways The FCA has published details of the ‘proportionate’, ‘flexible’ and outcomes-focused conduct regime it is proposing for newly regulated BNPL agreements. These include a pragmatic approach to documentation and a...more

A&O Shearman

HMT updates BNPL policy for domestic premises suppliers

A&O Shearman on

HM Treasury has published a policy paper setting out an update to its final position to its 2024 consultation on regulating Buy-Now, Pay-Later (BNPL) products which led to the laying of the draft secondary legislation, The...more

A&O Shearman

UK Government advances BNPL Regulation

A&O Shearman on

HM Treasury (HMT) has published a response to its 2024 consultation on regulating Buy-Now, Pay-Later (BNPL) products and laid the draft secondary legislation (Financial Services and Markets Act 2000 (Regulated Activities etc)...more

Skadden, Arps, Slate, Meagher & Flom LLP

UK Announces New Regime To Regulate ‘Buy-Now, Pay-Later’ Lending Following October 2024 Consultation

In October 2024, HM Treasury (HMT) published a consultation paper amid perceived concerns related to the “buy now, pay later” (BNPL) sector, including uninformed consumer decisions, affordability checks and levels of...more

Hogan Lovells

Buy-Now Pay-Later regulation: Government confirms final position

Hogan Lovells on

HM Treasury has confirmed its approach to the regulation of Buy-Now Pay-Later (BNPL) lending in its response to the October 2024 consultation. On 19 May 2025, Government also laid draft legislation before Parliament. Given...more

A&O Shearman

Buy Now Pay Later - The Journey Continues (and the end is nearly in sight)

A&O Shearman on

In an exciting week for consumer credit lawyers, in addition to the consultation paper on the reform of the Consumer Credit Act 1974 (CCA), we also have HM Treasury’s response to the feedback it received from the 61...more

Latham & Watkins LLP

UK Government Publishes Initial Proposals on CCA Reform

Latham & Watkins LLP on

Government consults on the first stage of reforming the UK consumer credit regime, covering information requirements, sanctions, and criminal offences....more

Latham & Watkins LLP

UK Government Sets Out Next Steps on BNPL Regulation

Latham & Watkins LLP on

On 19 May 2025, HM Treasury published its consultation response on the regulation of certain buy-now-pay-later (BNPL) products, setting out its final position, and laid a draft statutory instrument before Parliament to effect...more

Hogan Lovells

The Payments Newsletter including Digital Assets & Blockchain, May 2025

Hogan Lovells on

Key developments of interest over the last month include: draft legislation to regulate BNPL credit in the UK (in contrast to the de-prioritising of enforcement of BNPL regulatory breaches in the US); final confirmation of UK...more

Hogan Lovells

UK consumer credit reform and buy-now pay-later regulation – May 2025 developments

Hogan Lovells on

On 19 May 2025, HM Treasury released a suite of publications as part of its ongoing efforts to modernise the UK’s consumer credit framework. These include the Consumer Credit Act Reform – Phase 1: May 2025 Consultation, the...more

A&O Shearman

UK 2025 Regulatory Initiatives Grid published

A&O Shearman on

The Financial Services Regulatory Initiatives Forum (the Forum) has published the Regulatory Initiatives Forum Grid (the Grid), with the UK Financial Conduct Authority (FCA) also updating its webpage. The previous Grid was...more

A&O Shearman

UK FOS Plans and Budget published for 2025/2026

A&O Shearman on

The UK Financial Ombudsman Service (FOS) has published its plans and budget for 2025/2026, together with an accompanying press release. The FOS notes that there has been more uncertainty than usual over the last year, and...more

Hogan Lovells

FCA Annual Work Programme 2025/26: A work plan reflecting the UK government’s pro-growth mission

Hogan Lovells on

Motor finance, mortgage rule review work and Consumer Duty feature prominently in the work plans for this strategic priority. Firms should note that the FCA includes a warning in relation to the Duty that, where necessary, it...more

A&O Shearman

Buy-now, pay-later: what the future will (and might) hold for the sector

A&O Shearman on

KEY POINTS - - On the face of it buy-now, pay-later (BNPL), as an interest and charge free credit facility, appears low risk but couple its ready availability with the fact that it comes without any of the protections...more

Skadden, Arps, Slate, Meagher & Flom LLP

UK Proposes New Approach To Regulate ‘Buy Now, Pay Later’ Market Amid Rising Consumer Debt Concerns

In the UK, 14 million people used “buy now, pay later” (BNPL) at least once in the six months leading up to January 2023. Frequent users were more than four times as likely as other consumers to have missed a payment on a...more

Hogan Lovells

Buy-Now Pay-Later reform: UK government publishes updated proposals – now over to the FCA

Hogan Lovells on

HM Treasury has published its long-awaited response to the February 2023 consultation on its proposed approach to bringing Buy-Now Pay-Later (BNPL) within the FCA’s regulatory perimeter. The government is clear that “swift...more

A&O Shearman

Buy Now, Pay Later regulation – the wait is (nearly) over

A&O Shearman on

It has been a long time in gestation but finally, over three and a half years after the Woolard Review highlighted the potential risks of unregulated, but easily available, interest free credit facilities, we have the...more

White & Case LLP

Sector trends - September 2024: Consumer Finance

White & Case LLP on

UK & European Financial Services M&A: Sector Trends H2 2023 | H1 2024 — Consumer Finance - Current market: Inflexion point for UK & European consumer lending - We are seeing: Significant consolidation activity: ...more

Hogan Lovells

The Payments Newsletter including Digital Assets & Blockchain, July 2024

Hogan Lovells on

Key developments of interest over the last month include: the Bank of Italy’s communication on unauthorised payment transactions; the Reserve Bank of Australia’s announcement of an upcoming review into retail payments...more

Latham & Watkins LLP

Is the Customer Always Right? PE in Focus as Regulators Tighten Grip on Consumer Facing Companies

Latham & Watkins LLP on

Consumer-facing companies face an increasingly complex UK regulatory landscape as multiple regulators place the spotlight on consumer rights and protections. A raft of new legislation is set to impact businesses and PE...more

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