FinTech Buy Now Pay Later Platform — UK Regulated BNPL Provider

FSMA 2023 regulated BNPL

interest-free deferred payment agreements are now regulated credit under the Consumer Credit Act.

Key FCA requirements

(1) affordability assessment (proportionate to BNPL credit risk —

FCA guidance

soft credit check minimum, income verification for larger amounts). (2) CONC pre-contract information: clear BNPL terms before checkout. (3) forbearance: customers in financial difficulty must be offered payment plans. (4)

Consumer Duty

value assessment (is BNPL fair value vs alternative finance?), consumer understanding (are BNPL terms understood before purchase?).

Retail Partner API Integration

• 85 retail partners: headless BNPL checkout widget (React — drops into any retailer's checkout), BNPL REST API (partner backend integration — order creation, refund, cancellation), webhook events (payment received, late payment, full repayment).
• OpenAPI 3.0 specification: published to retail partners as machine-readable API documentation (FCA COBS machine-readable disclosure).

Partner onboarding

Companies House verification, bank account verification (Creditsafe), and merchant agreement (DocuSign).

Soft credit check

Experian API (soft search — no credit file footprint, customer-consented).

Income estimation

open banking AISP (TrueLayer — 3 months income/expenditure) for purchases above £250.

Credit limit calculation

purchase history (repeat customers with good repayment get higher limits), Experian score, and income estimation.

Credit limit transparency

customer can see their BNPL limit and how it is calculated — FCA Consumer Duty Consumer Understanding.

FCA CONC

debt collection must be fair and not cause harm.

Late payment flow

Day 3 (SMS reminder — GOV.UK Notify), Day 7 (email reminder with payment link), Day 14 (formal arrears notice — Consumer Duty vulnerable customer assessment), Day 21 (payment plan offer — automatically generated based on outstanding balance and estimated income), Day 60 (default, credit file marker).

Vulnerable customer

if customer indicates financial difficulty at any stage, mandatory payment plan offer — no additional fees.