Project Overview
A UK retail SaaS provider (serving 3,400 independent retailers) wanted to add embedded financial services to t...
Technology Stack
Compliance & Standards
The Challenge
A UK retail SaaS provider (serving 3,400 independent retailers) wanted to add embedded financial services to their platform — specifically: BNPL (Buy Now Pay Later) for retailer customers, business current account (Embedded Banking), and invoice financing. FCA Consumer Credit Act (BNPL), FCA EMI regulations for the embedded account, UK GDPR, and Banking-as-a-Service (BaaS) partner integration were the requirements. Budget: £130,000.
Our Approach
BNPL Architecture with FCA CCA Compliance
- BNPL is regulated credit under the Consumer Credit Act 1974.
- FCA Consumer Duty applies.
Credit decision engine
- soft credit search (Experian) for pre-approval, affordability calculation, fraud scoring (Emailage, device fingerprint).
- CCA-compliant agreement generation: pre-contract credit information (PCCI) in FCA-prescribed format, cooling-off rights, default and arrears process in accordance with FCA CONC.
- BNPL above £200: full CCA regulated agreement required.
Embedded Banking via BaaS
Banking-as-a-
Service partner
Modulr (FCA-authorised EMI) for embedded business current account.
Modulr API
account creation, sort code/account number provisioning, inbound/outbound Faster Payments, Direct Debit origination, and transaction data.
UK GDPR
Modulr is a data controller for account data — joint controller agreement required.
FCA oversight
activity conducted under Modulr's EMI licence (agent registration required).
Funding Circle Invoice Finance API
eligible invoices uploaded from retailer's SaaS sales ledger (automated — no manual upload), advance rate calculation (80% of eligible invoice value), advance payment via Faster Payments to retailer current account.
Invoice maturity
automatic repayment on invoice settlement.
Collections
Funding Circle handles collections — retailer remains primary obligation holder.
FCA Consumer Duty for Embedded Finance
Consumer Duty four outcomes applied to embedded financial products.
Consumer Understanding
- BNPL terms in plain English (Flesch >
- 65) — not buried in checkout.
Price and Value
BNPL APR clearly disclosed.
Consumer Support
dedicated financial services support pathway (separate from SaaS product support).
Regulatory oversight
ClickMasters recommended appointing a dedicated Appointed Representative (AR) compliance officer for FCA notification.
The Results
Platform live at 16 weeks, £122,000 — under budget.
BNPL adoption: 18% of eligible transactions in first 3 months.
Retailer current account uptake: 34% of active retailers (1,156 accounts) in 6 months.
Invoice financing: £2.1M advanced in first 6 months.
FCA Consumer Duty review: zero adverse findings.
AR registration with FCA: completed at platform launch.
Net Revenue Retention uplift: platform ARR increased 28% from financial services revenue share.
“28% ARR increase from financial services revenue share — that is the embedded finance thesis proven in our market. The FCA compliance architecture was the hardest part and ClickMasters got every detail right. 1,156 embedded current accounts in 6 months validates the product-market fit." — CEO, UK Retail SaaS Provider (name withheld)”
Project Details
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