The UK’s new Buy Now Pay Later protections do not cover every instalment purchase. For the newly regulated form of interest-free credit, two questions are crucial: was the agreement made on or after 15 July 2026, and is the lender a different business from the seller?
The Financial Conduct Authority’s consumer guidance, updated in August, calls this product Deferred Payment Credit, or DPC. It is interest-free borrowing repayable in no more than 12 instalments over no more than 12 months.
Which agreements remain outside the new regime?
DPC taken out before 15 July remains unregulated under these changes. The same is true where the business selling the goods also provides the DPC itself. Other products marketed as Buy Now Pay Later can have different rules, so the label on a checkout button is not enough.
For example, a purchase financed by a separate lender after the start date differs from a retailer’s own interest-free arrangement. That distinction concerns regulatory coverage, not a judgment about either seller.
What must regulated lenders now do?
The FCA’s final-rules announcement sets out proportionate affordability checks, clearer information about repayments and late fees, and support for customers in financial difficulty. The Consumer Duty also applies.
A lender may operate under the temporary permissions regime while seeking full authorisation. That is not the same as being exempt from the new conduct rules. The FCA’s consumer page explains how to check a lender’s status.
Can you complain to the Financial Ombudsman?
The Financial Ombudsman Service explains that eligible complaints about newly regulated BNPL can now come to its free, independent service. Complain to the provider first; if the issue is not resolved, follow the Ombudsman’s process and time limits.
This is a route for examining a dispute, not an automatic refund or a cancellation of money owed.
Does Section 75 cover a faulty purchase?
MoneyHelper’s guide explains that Section 75 protection has been extended to qualifying BNPL agreements. The usual item-price range is more than £100 and up to £30,000, and other conditions apply. A provider’s voluntary buyer-protection policy is separate from a statutory right.
Regulation does not make instalments free money. Several small agreements can leave repayments falling due together. The practical question remains the total owed across providers, not just the size of the next payment.
Reporting basis: FCA, Financial Ombudsman and MoneyHelper guidance checked on 3 September 2026. General consumer information, not personal borrowing or legal advice.
Illustrative online shopping photograph; no lender or payment product is endorsed. Photo by rupixen on Unsplash