FinTech Buy Now Pay Later Platform — UK FCA Authorised

FCA consumer credit regulation of BNPL

from 2026, BNPL products are regulated credit agreements under CCA.

Regulated BNPL requirements

• 1credit agreement (CCA Section 61 — written credit agreement, prescribed terms, cooling-off right),
• 2creditworthiness assessment (FCA CONC 5.2A — assess affordability before granting credit),
• 3APR disclosure (CCA Section 20 — Annual Percentage Rate must be disclosed even for 0% interest BNPL),
• 4pre-contractual information (SECCI — Standard European Consumer Credit Information — standard form required by FCA),
• 5FCA credit register reporting (credit bureau reporting — positive and negative data — from credit agreement start).

Platform

credit agreement generation, SECCI generation, APR calculation engine (actuarial — correct APR for 0% BNPL), credit bureau reporting via Experian/Equifax B2B API.

Open Banking Affordability Assessment

FCA CONC 5.2

A creditworthiness assessment

lender must consider income, committed expenditure, and any other credit before approving BNPL.

Open Banking affordability

• 1TrueLayer AISP (6-month bank account transaction history — customer consents),
• 2income identification (salary credits, regular income patterns — ML categorisation),
• 3committed expenditure (rent/mortgage, utility direct debits, loan repayments — ML categorisation),
• 4disposable income (income minus committed expenditure),
• 5credit affordability check (BNPL repayment as % of disposable income — FCA stress test at +3% interest rate even for 0% product).

Credit bureau

Equifax CreditScore API (CCJs, defaults, existing credit commitments).

Automated decision

• income - committed expenditure - existing credit repayments - BNPL repayment &gt
• £0 and creditworthy → approve.

FCA Consumer Duty PS22/9 for BNPL

BNPL Consumer Duty obligations are the most scrutinised of all credit products.

Consumer Duty design principles

• 1product suitability — BNPL is not suitable for financially vulnerable customers (gambling-related spend, patterns suggesting over-indebtedness → decline),
• 2price and value — 0% BNPL is genuine value only if merchant discount rate (MDR) does not lead to higher retail prices being passed to non-BNPL customers,
• 3consumer understanding — plain English credit agreement (Flesch-Kincaid Grade Level < 8 — automated readability check),
• 4consumer support — missed payment communication must be supportive, not threatening — FCA Consumer Duty tone of voice guidelines.

Vulnerable customer identification

open banking data flags potential vulnerability (gambling transactions, consistent overdraft, late payment patterns) → automatic referral to vulnerability support pathway (not decline — FCA expects engagement not exclusion).

Merchant integration

BNPL embedded at checkout (Shopify app, WooCommerce plugin, and headless JavaScript SDK).

Merchant flow

• 1customer selects BNPL at checkout,
• 2BNPL platform creates credit agreement (pre-filled from merchant basket data),
• 3customer completes identity verification (Onfido) and affordability check,
• 4credit approved → BNPL platform pays merchant in full within T+1 (GoCardless B2B payment),
• 5customer repays BNPL in instalments (3/6/12 months — GoCardless VRP — Variable Recurring Payments).

Merchant discount rate

2–4% of transaction value (merchant pays for BNPL service).

FCA register

BNPL platform registered as credit broker (and lender if funding from balance sheet) — credit register listing shown at checkout (FCA requirement).