From 1 November 2026, Buy Now Pay Later (BNPL) products — deferred payment plans where the consumer pays in instalments after taking delivery — become regulated consumer credit products under the Financial Services and Markets Act 2023. BNPL lenders must be authorised by the Financial Conduct Authority (FCA) and comply with FCA consumer credit rules. Key changes for consumers:
Creditworthiness assessments: BNPL lenders must assess whether you can afford to repay before extending credit. Section 75 rights: BNPL agreements that are linked credit agreements (connected to a specific purchase) will now attract s.75 of the Consumer Credit Act 1974 protection — if the goods or services are defective or not delivered, you can claim against the BNPL lender as well as the retailer. FOS complaints: you can complain to the Financial Ombudsman Service (FOS) about BNPL lenders, which was not possible under the previous unregulated regime. Right to information: you must receive a pre-contract credit information document and have 14 days to withdraw. Any existing BNPL agreement entered before 1 November 2026 is not retrospectively regulated but any renewal or extension from that date is.
For related consumer rights, see the faulty goods refund guide and the Digital Markets Act article.