From 15 July 2026, Buy Now Pay Later (BNPL) becomes regulated "Deferred Payment Credit" (DPC), with full FCA oversight of disclosures, creditworthiness checks, conduct standards, complaints handling and customer communications. Third‑party lenders, not merchants, sit in the FCA regulated perimeter. However, lenders will now need to flow down mandatory customer‑facing information, which merchants must "surface" in e‑commerce, app and in‑store journeys.
Impact: This will land on product, UX, marketing and retail operations teams fast, and GCs might be best to get ahead of the changes, alerting internal stakeholders, before conversion or brand experience suffer.
1) The changes are happening soon!
The FCA's final rules were published on 11 Feb 2026, and lenders enter the Temporary Permissions Regime from 15 May 2026, before full regulation kicks in on 15 July 2026.
This is a tight window for merchants to absorb lender‑driven documentation and update their own customer journeys, even if website code, user journeys and campaigns, are not hard-wired.
2) What information obligations will merchants need to push to consumers?
Because DPC becomes regulated credit, lenders must now provide:
- Mandatory pre‑contract information
- Clear and timely disclosures on:
- repayment structure
- risks of missed payments
- rights, protections and complaints routes
Enhanced post‑contract and missed‑payment communications
Lenders must send specific notices and support communications; they may require merchants to surface certain messages or handoff paths.
Creditworthiness‑linked prompts
CONC 5.2A creditworthiness rules now apply to DPC. Lenders may require merchants to provide or collect extra data at checkout or integrate new credit‑decisioning screens.
Complaints‑handling pathways
Clear signposting of how customers escalate issues to the lender (and ultimately the FOS). This may require specific language in confirmation pages, order emails and receipts.
These obligations will not originate from the merchant, but lenders will in practice require merchants to display or integrate them.
3) What problems might this cause for merchants?
A. UX & conversion friction
New mandatory disclosures risk cluttering checkout flows and harming conversion, especially on mobile. Lenders may push conservative wording that feels "scary" or off‑brand.
B. Tech and design changes with aggressive lead times
Checkout, emails, CRM, store till prompts, app flows, and on‑premise POS terminals may all need modification. Many dev teams already have locked sprints through spring/summer.
C. In‑store BNPL complications
In‑person journeys are the hardest: POS terminals, staff scripts, printed materials, handoff to lenders, and real‑time creditworthiness checks all become more complex.
If lenders require specific disclosures before a customer signs up, retailers will need redesigned physical or digital flows.
D. Tight sequencing with FCA Consumer Duty and consumer law
Even though merchants themselves are not regulated for DPC, consumer law still applies, meaning:
- the combined BNPL information and merchant sales flow must still be fair, intelligible and not misleading
- duty to ensure overall customer understanding sits partly with the merchant
- returns/refunds and chargebacks must integrate cleanly into the lender's processes
If lenders' wording is too legalistic, merchants risk consumer‑law non‑compliance even if FCA rules technically sit with the lender.
4) What GCs might do now...
(1) Check with BNPL lenders to confirm they are entering FCA regulation
All third‑party DPC lenders must be authorised or enter the TPR. If your lender is unprepared, merchants risk sudden commercial disruption
(2) Ask lenders for their "Regulation Day" documentation ASAP
This may include:
- changes to your lender contract
- required customer disclosures
- updated customer wording
- technical integration requirements
(3) Map what needs to be flowed down into consumer journeys
This includes checkout flows, order confirmations, emails, SMS, CRM sequences, and in‑store journeys.
(4) Be ready to challenge lender overreach
If lender‑mandated wording is:
- too long,
- too risk‑heavy,
- conversion‑killing, or
- inconsistent with consumer law,
you may need to push back. FCA rules require clarity, not fear‑mongering. You should not accept language that destroys UX or contradicts consumer‑law obligations.
(5) Coordinate internally: product, marketing, retail ops, store staff
This is cross‑functional. And think about the in‑store impact as well as the online one.
(6) Review your end‑to‑end consumer law compliance
The FCA may not regulate you directly — but the overall customer journey remains subject to UK consumer protection law. Ensure the combined merchant + lender disclosures are coherent, accurate and non‑misleading.
5) How we can help - We are already advising clients on:
- BNPL change audits for merchants
- Review and negotiation of lender‑issued documentation
- Consumer journey rewrites to meet FCA‑driven obligations without harming conversion
- Integration of BNPL changes into wider consumer‑law frameworks
- Training for marketing, UX and retail teams on the new obligations
- Consumer Duty alignment
If we can support you, whether as an end‑to‑end project or a rapid "BNPL impact triage", we'd be happy to help.
