This article is for general information only. It is not financial advice and does not recommend a specific lender or product.

Buy now, pay later (BNPL) products are expected to come under formal Financial Conduct Authority (FCA) regulation on 15 July 2026. This date is subject to confirmation in the FCA's forthcoming policy statement and the HM Treasury statutory instrument bringing BNPL within the regulated credit framework; final rules have not yet been published.

What is changing?

  • BNPL products, offered at checkout by providers such as Klarna and Clearpay, are currently outside the main consumer credit regulatory framework.
  • From 15 July 2026 (expected, subject to final confirmation by the FCA and HM Treasury), firms offering BNPL will need FCA authorisation to operate.
  • Authorised providers will be required to carry out affordability checks before lending, provide clearer information about repayment terms, and offer formal complaint routes, including access to the Financial Ombudsman Service.

These requirements bring BNPL broadly in line with other regulated consumer credit products.

Why it matters

At the moment, a shopper can take on BNPL debt at checkout with fewer protections than they would have with a credit card or personal loan. From July, providers will need to treat BNPL as what it is: a credit product with real repayment obligations.

For shoppers, the practical effect should be clearer terms, stronger affordability checks and a defined route to complain if something goes wrong.

In practice, an affordability check might mean a provider asks you to confirm your monthly income and outgoings before approving a BNPL arrangement, or runs a soft credit search to assess whether the repayments are manageable alongside your existing commitments. CP24/2 sets out a proposed proportionate assessment framework, meaning the depth of the check may be scaled to the size and risk of the credit being offered. The exact process will vary by provider once the rules are finalised.

Who may be affected

  • Anyone who uses BNPL regularly at checkout, particularly across multiple providers at once.
  • Shoppers with existing BNPL balances when the rules come into force.
  • People who have used BNPL without fully tracking how much they owe in total.

If you have BNPL balances from more than one provider, it can help to add them up and consider how the repayments sit alongside rent, bills and other credit commitments.

If you are concerned about existing BNPL debt or other borrowing, free and impartial help is available from StepChange Debt Charity and MoneyHelper. Both services can help you review your options without charge.

CP24/2 also proposed that BNPL debt should begin to appear on credit files once providers are fully regulated. As of the last review date of this article, this remains a proposal and neither the FCA nor the main credit reference agencies (Experian, Equifax and TransUnion) have confirmed reporting timelines; the position will depend on individual providers once final rules are in place.

What about agreements signed before 15 July 2026?

BNPL agreements entered into before 15 July 2026 will generally not be covered by the new rules. The FCA's framework is expected to apply to agreements made on or after that date. If you have existing BNPL balances, the terms you agreed to at the time of purchase will continue to govern those arrangements, and the new complaint and affordability protections will not apply retrospectively to them.

If you have a dispute about an existing BNPL agreement, you may want to check whether your provider has a formal complaints process and, if that does not resolve the matter, whether you can refer the complaint to the Financial Ombudsman Service. Please note that FOS jurisdiction over unregulated BNPL agreements entered into before the July 2026 implementation date may be limited, and the FOS may not be able to consider complaints about such agreements. However, some BNPL providers have voluntarily joined the FOS scheme ahead of regulation, which means FOS access before July 2026 may exist depending on your provider. It is worth checking directly with your provider or the FOS to confirm whether your agreement falls within their remit.

This article will be updated when the FCA publishes its policy statement (PS25/3) and the HM Treasury statutory instrument is laid, as both may affect the details described above.

What to read next

For a fuller explanation of how BNPL works and what the regulation means in practice, see our guide to buy now, pay later.

To understand how other forms of borrowing compare, the credit cards guide and the personal loans guide cover the regulated alternatives in plain terms.

Sources

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