Preparing for the FCA's new Buy Now Pay Later rules - 15 July 2026

With the changes to Buy Now Pay Later (BNPL) coming into force from 15 July 2026, now is the time for firms affected by the changes to review processes, systems and get ahead before the effective date. If your teams are currently working through what the changes mean for your business, our detailed guidance below breaks down each requirement and provides practical steps to prepare.

1. Affordability & Creditworthiness Assessments

BNPL credit providers must conduct proportionate and robust affordability and creditworthiness checks before offering credit. This includes evaluating ability to repay and long‑term financial impact.

Practical Steps:

• Run a readiness gap-scan against the final FCA rules and Consumer Duty.
• Map BNPL journeys and insert checks with minimal friction.
• Upgrade affordability engines (soft searches, income verification, Open Banking).
• Define proportionality rules.
• Build audit trails for regulatory scrutiny.

2. Pre‑Contract Information Requirements

Customers must receive clear, concise, and useful information before entering a BNPL agreement.

Practical Steps:

• Redesign pre-contract information screens using plain English.
• Test understanding with customer panels.
• Validate pre-contract content against CONC requirements.

3. Missed Payment Communications

Communications must be clear, accurate, empathetic, and timely.

Practical Steps:

• Rewrite scripts to ensure supportive tone and signposting to free debt advice.
• Review automated triggers for accuracy.
• Embed outcome testing under Consumer Duty.
• Conduct vulnerability assessments.

4. Financial Ombudsman Service Access

BNPL customers can escalate disputes to the FOS.

Practical Steps:

• Update complaints policies.
• Train staff on FOS standards.
• Implement centralised complaint tracking.

5. Consumer Duty Obligations

BNPL firms must demonstrate good outcomes, fair value, and adequate oversight to comply with Consumer Duty obligations.

Practical Steps:

• Train staff on Consumer Duty obligations.
• Build outcome‑testing frameworks.
• Update MI dashboards.
• Perform fairness assessments.

6. Systems, Processes & Data Flow Updates

Systems must support regulated decisioning, documentation retention, and communication trails.

Practical Steps:

• Conduct a data‑flow audit.
• Implement new SOPs.
• Upskill teams on regulatory BNPL touchpoints.

7. Balancing Compliance With Experience

Maintain frictionless journeys while embedding checks.

Practical Steps:

• Apply progressive friction.
• Use pre‑filled information.
• Test conversion impacts.

8. Preparation Roadmap

Phase 1: Diagnostic (Now – Q2 2026)

Phase 2: Redesign (Q2 – Q4 2026)

Phase 3: Implementation & Training (Q4 2025 – July 2026)

Phase 4: Post‑Implementation Review (July 2026 onwards)