Buy Now Pay Later Regulation: Where It Stands

Regulation of Buy Now Pay Later products continues to develop, bringing previously unregulated short-term credit products within a more formal consumer credit framework, with implications for affordability assessment and disclosure requirements.

Firms operating BNPL products, and retailers embedding them at point of sale, should treat this as a genuine regulatory transition requiring operating model change, not a labelling adjustment — affordability assessment in particular is likely to require materially different infrastructure than many current BNPL providers have in place.

We're advising clients in this space to begin building affordability assessment capability now, ahead of formal requirements crystallising, given the lead time genuine operating model change of this kind typically requires.

This briefing reflects Alden Advisory's general commentary on a developing regulatory topic and is not legal or regulatory advice. Firms should seek specific guidance for their own circumstances.