Following concerns about potential material consumer indebtedness arising from the exponential growth in the ready availability of buy-now, pay-later (BNPL) credit products, and some four years after the 2021 Woolard Review concluded urgent action was needed to address that, 2025 is set to see the enactment of legislation that brings the majority of traditional BNPL within the scope of the Financial Service and Markets Act 2000 and the Consumer Credit Act 1974. The Financial Conduct Authority is then charged with delivering a tailored conduct of business framework so that, in 2026, most BNPL will be offered within a regime that provides appropriate levels of consumer protection while ensuring that lenders are not deterred from continuing to offer these useful interest-free products. This article examines the new regulatory perimeter, how the proposals aim to meet the requirements for proportionality and protection and what the alternatives might be for existing lenders.

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