Buy now pay later has been FCA-regulated since 15 July 2026. Two industry voices explain what changed in affordability checks and complaints, and the record shows where providers still fall short.

For years, buy now pay later sat outside UK credit rules. A shopper could split a purchase into three payments with almost no friction and no formal BNPL affordability check. That ended on 15 July 2026, when the FCA started regulating deferred payment credit. BNPL affordability is now a legal duty, not a design choice.

So we asked industry leaders one question: now that BNPL is regulated, what has changed in how your business checks affordability or handles complaints, and what are providers still getting wrong? We wanted specific process changes over general opinion. Two respondents answered. Below, we set their replies against the rules and the early record.

What the FCA rules require

The FCA published its final rules in policy statement PS26/1 in February 2026. The scale explains the urgency. The regulator says deferred payment credit grew from £0.06 billion in 2017 to over £13 billion in 2024. In addition, its Financial Lives survey found 10.9 million UK adults used the product in the year to May 2024.

Under the new regime, BNPL affordability checks apply to every agreement, including purchases of £50 or less. Lenders must also show repayment dates and late fees before the customer signs. The FCA’s guide for consumers adds that complaints can now go to the Financial Ombudsman Service. However, only agreements made from 15 July 2026 are covered.

BNPL affordability is now a lending decision

Our first respondent framed the change as a shift in mindset as much as process.

“The biggest change is that BNPL providers now have to treat affordability as a lending decision, not a checkout conversion. Since the FCA began regulating deferred payment credit on 15 July 2026, lenders must run proportionate affordability checks, set out repayment dates and late fees before the customer signs, and support people who fall into financial difficulty. The FCA puts the market at more than £13 billion in 2024, up from £60 million in 2017, so this is now a mainstream product.

In practice, the hard part is looking at a customer’s existing credit and their real ability to repay, rather than leaning on the basket value or an automated approval score. Complaints need clearer handling too: how affordability concerns get investigated, how decisions get explained, and when an unresolved case goes to the Financial Ombudsman Service.

The mistake I still see is treating a missed payment as a collections problem when it may be the first sign of financial distress. Good compliance means watching repayment patterns, spotting repeat borrowing and offering forbearance before things get worse. The rules only mean something if they change who gets approved, not just how the policy reads.”

Arvind Rongala, CEO, Edstellar

His point on missed payments matches the BNPL affordability rules in PS26/1. The policy statement says a lender should check income and spending when a past customer has missed payments, even if they later caught up. The same applies when several active plans add up to a real affordability risk. Still, the rules allow lighter BNPL affordability checks where there is clearly no material risk, as long as firms can show why.

Open Banking helps, but the rules do not require it

Our second respondent focused on the data behind each BNPL affordability decision.

“The FCA rules have pushed BNPL away from growth at any cost towards lending that can stand up to scrutiny. The biggest process change we see is a move away from static credit scores towards affordability checks that use Open Banking data. Instead of relying on payment history alone, providers are building systems that read live transaction data to estimate how much a customer can spare when they check out. That means building proper data pipelines into the checkout, not bolting them on.

Complaints have changed too. Providers now need a formal dispute process that looks much more like a bank’s. We’re also seeing more monitoring tools that flag signs of distress, or people juggling several BNPL plans, before the customer complains. That gives providers a chance to step in early with support or a lower limit.

The main thing providers still get wrong is treating compliance as a reporting layer. Too many firms add affordability checks to the front end or through an API overlay, and end up with data silos and friction. The checks have to sit in the core decision engine, so every approval can be defended in an audit. Ignoring what a customer owes other providers, or relying on stale credit data, is still a real risk.”

Abhishek Pareek, Founder and Director, Coders.dev

Open Banking is a real tool for BNPL affordability, but it is optional. The FCA says some lenders use it to fill gaps in credit files, and that this can comply with its rules. Zilch has used bank data since 2020, while Klarna offers it as an opt-in step. Meanwhile, most big providers still rely mainly on soft credit checks, Which? reported.

Credit files still have gaps

His warning about other providers’ debts points to the weakest link in BNPL affordability. Lenders do not have to report BNPL plans to credit reference agencies. Klarna reports to Experian and TransUnion, while Clearpay says only that missed payments may be reported. As a result, one lender often cannot see a customer’s plans with another.

The FCA wants to close that gap. In consultation CP26/7, it proposed that firms sharing data with one major agency must share with all three. That would cover deferred payment credit too. For a wider look at data checks on business customers, see our roundup on beneficial ownership rules.

Complaints and arrears now run on regulated clocks

Complaint handling has changed as much as BNPL affordability checks. Lenders must now contact a customer as soon as possible after a missed payment, set out what is owed and explain the consequences. They must also signpost free debt advice before taking action. The Financial Ombudsman Service expects around 2,000 BNPL complaints in its 2026/27 year, mostly in the second half.

Demand for help is already rising. Citizens Advice helped 7,468 people with a BNPL problem in 2025, up 35% on 2024. Therefore, weak BNPL affordability checks at checkout tend to surface later as arrears and complaints.

What providers are still getting wrong

Several gaps in BNPL affordability remain. First, debt charities have questioned whether late fees reflect the real cost of collection. Second, checkout design can blur the line between paying and borrowing, especially when a retailer shows four or five BNPL brands. Third, customers still have no single view of everything they owe across lenders.

Competition is also shifting. Affirm launched instalments on Amazon UK in September with no late fees. Pay-over-time is spreading in stores too, as our report on Zip at Best Buy showed. UK lenders are widening their credit ranges as well, as seen in Revolut’s UK personal loans.

What to watch next

Several dates will test BNPL affordability rules in 2027. Firms in the temporary permissions regime must apply for full authorisation by mid-January 2027. The FCA is also expected to finalise its credit data sharing rules around the end of 2026. In addition, the first ombudsman decisions on BNPL will show how strictly checks are judged.

Taken together, the lesson is simple. BNPL affordability is no longer a box at checkout. It is a lending decision that has to hold up months later, when a payment is missed and a complaint arrives.

FintechBits covers payments, banking and fintech developments for readers in the US and UK. This article is for information only and is not financial or legal advice. Views expressed are those of the FintechBits editorial team.