The FCA has now finalised the rules for Buy-Now-Pay-Later (BNPL, but called Deferred Payment Credit or DPC by the FCA) which are due to enter into force this Summer. 

The final rules set out in PS26/1 largely follow the consultation proposals released last year, but include a number of refinements. These are particularly noticeable in the information and disclosure requirements that apply before, during, and after a DPC agreement.

The rules affect forms of interest-free credit repayable in 12 months or fewer. The key parts of the new rules include:

• DPC providers will come under FCA regulation from 15 July 2026.
• Firms will be required to provide key product information (KPI) to consumers before they enter into an agreement.
• The FCA will apply Consumer Duty rules. Regarding the Duty, the FCA reminded firms of their obligations under the consumer understanding and consumer support outcomes.
• Firms will be required to undertake proportionate affordability checks.
• The rules require firms to provide information when consumers miss repayments, and to give notice before they take any action as a result. It also requires DPC lenders to provide information about free debt advice in certain circumstances.

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Rule clarifications

There were a few areas where the FCA has made some relatively limited, but still important changes from the proposals they consulted on last year.

Refined “Key Product Information” (KPI):

• The FCA scaled back some of the KPI requirements to reduce “consumer information overload”, and following concerted lobbying from firms afraid it would create too much friction at the checkout.
• Specifically, they removed some areas from the mandatory KPI.  These include information concerning:
  
  • Details of withdrawal, cancellation and early repayment rights.
  • Right to complain to the Financial Ombudsman Service (FOS).
  • Explaining continuous payment authorities.
• These items are now part of “additional product information” that firms must give or make available before agreement, and the KPI must signpost where these details are available in an easily accessible form.

This change is a refinement rather than a scaling-back of consumer protection per se. The information still needs to be available, but the format of its upfront disclosure has been narrowed to prioritise what the FCA considers decision-critical facts.

Credit Reference Agency (CRA) Disclosure: The final rules clarify that firms must tell consumers whether they will or may obtain credit reference information, recognising that some lenders may not know at the KPI stage if a CRA check will be used.

Missed Payment Communications: The policy statement makes this clear. Firms need to notify the customer of a missed payment and provide sufficient information to understand the specific agreement, immediate/future adverse consequences, and steps to mitigate harm. The language in the final Handbook text (CONC 7.20) reflects this structured requirement.

Debt Advice Signposting: The final rules now explicitly require that, before enforcement action or termination, firms signpost free and impartial money guidance and debt advice resources. This language mirrors the CONC requirements for other regulated credit.

The Ombudsman and Dispute Resolution: Under the final rules consumers will have FOS access for regulated DPC complaints from Regulation Day onwards, a significant consumer protection outcome. However, firms will only need to reference this in the Additional Product Information.

Early signs are that DPC providers, such as Klarna and Clearpay, have largely welcomed the balanced approach, saying it raises standards while avoiding overly burdensome disclosures.

For consumers it should result in a much more informed decision and, the FCA hopes, lead to less debt arising from the currently unregulated way to pay.

Amplifi Global is developing a consumer understanding-led journey to comply with the new regulations and provide firms with confidence that they meet the FCA expectations.  Contact us to find out more.

To read more on how making BNPL communications more intelligible will help both consumers, firms and retailers, take a look at our recent blogs.