Buy now, pay later: Consultation now, regulation soon
12 November 2024
On 17 October 2024, HM Treasury launched a six-week consultation on draft legislation to bring buy-now pay later (BNPL) products into the scope of regulation by the Financial Conduct Authority (FCA). The draft legislation builds on draft legislation previously published in February 2023 under the previous government (which itself was proposed by the Woolard Review in February 2021).
The consultation closes on 29 November 2024. The legislation is expected to be made in early 2025 with full implementation of the BNPL regime expected twelve months later, in Q1-Q2 2026. A temporary permissions regime (TPR) will apply to unauthorised BNPL firms pending FCA authorisation.
In this briefing, we outline the key elements of the proposed BNPL regulatory regime, and the potential impacts for affected firms and users of BNPL products.
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