Fee Structure Inputs

Regulatory regimes to check

🇬🇧 FCA HCSTC cap

High-cost credit · £15 hard cap per event

🇬🇧 FCA Standard / DPC (CONC 7)

Non-HCSTC · proportionality test · Consumer Duty

🇪🇺 EU CCD2 Art. 33

Default charges must be fair & proportionate

🇺🇸 CFPB Reg Z / UDAAP

Closed-end BNPL · proportionality · UDAAP

🗽 NY DFS BNPL Guidance

New York State · Jun 2023 guidance

Select at least one regime.

Reporting currency

Late fee structure

Late fee amount

Enter the fixed late fee charged per missed payment event.

Late fee rate (% of outstanding balance)

Average outstanding balance at default (£)

Used to convert % fee to flat equivalent for regulatory comparison.

Tier 1 — small balance (e.g. under £100)

Tier 2 — mid balance (£100–500)

Tier 3 — high balance (over £500)

Each tier is assessed independently. Worst-case tier drives the compliance verdict.

Estimated affected customers (for remediation calc)

Number of customers charged non-compliant fees. Leave blank to skip remediation estimate.

Months of non-compliant charging

Average missed payment events per customer per month

Industry typical: 0.3–0.8 late events per active customer per month.

Please check your inputs.

← Complete inputs and click Calculate to see results

Source Notes, Regulatory Caps & Methodology

FCA CONC 7B — High-Cost Short-Term Credit (HCSTC) default fee cap: maximum £15 per default event; applies when: APR ≥ 100% or term ≤ 12 months and amount ≤ £25,000. Source: FCA Handbook CONC 7B.4.1R, CONC App 1.2. The £15 cap has been in force since January 2015 (FCA PS14/16).
FCA CONC 7.7.4R — Standard consumer credit: firms must not impose charges exceeding what is necessary to compensate for costs reasonably incurred as a result of the default. No hard cap exists for non-HCSTC credit. The £25 reasonableness proxy is derived from FCA CP23/5 (BNPL consultation) market data and industry practice; it is indicative, not a published FCA threshold. Consumer Duty (PS22/9) requires fees to represent fair value from July 2026.
Directive 2023/2225/EU (CCD2), Art. 33 — member states must ensure default charges are fair, transparent and proportionate to costs incurred. CCD2 does not set an EU-wide cap; national implementing legislation applies. Indicative member state caps used: Germany § 503 BGB (5 pp above ECB base rate ≈ 7.6% p.a. as at May 2026); France Art. L.312-19 (2× legal rate = ≈10.2% p.a.); Italy applies usury law limits. These are indicative upper bounds; actual caps may differ post-transposition.
CFPB Regulation Z (12 CFR 1026) — no hard dollar cap on late fees for closed-end BNPL credit. CFPB's $8 late fee safe harbor (finalized March 2024) applies to large credit card issuers (open-end credit), not closed-end BNPL. For BNPL: fees must be reasonable and proportionate per Reg Z commentary. CFPB Supervisory Highlights Spring 2023 flags fees exceeding $30 on small BNPL transactions as a UDAAP risk area. The $30 supervisory focus threshold used here is indicative, derived from CFPB examination guidance, not a hard rule.
NY DFS BNPL Supervisory Guidance (June 2023), §2 — late fees must be reasonable and proportionate to the outstanding balance and the nature of the default. No hard cap published as of May 2026. The $15 reasonableness proxy reflects NY DFS examination expectations and CFPB comparative analysis; it is indicative only.
Remediation methodology: estimated remediation = (your_fee − max_permitted_fee) × customers × months × events_per_month. Where the applicable regime has no hard cap, the reasonableness proxy is used as the ceiling. This estimate is illustrative only; actual remediation scope requires legal assessment including limitation periods (UK: 6 years from cause of action; EU: varies by member state; US: TILA statute of limitations 1 year for individual claims).
Status thresholds: Compliant = at or below cap/proxy; At Risk = above proxy but below 2× cap (enforcement attention zone); Non-Compliant = above hard cap. For regimes with no hard cap, At Risk = proxy+1 to proxy×1.5; Non-Compliant = above proxy×1.5. Client-side only. Zero PII.

Late Fee & Penalty Compliance Calculator