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Scope: Compliance Methodology Assessment Only. This tool evaluates whether a BNPL provider's affordability assessment methodology meets regulatory minimum requirements. It does not make, model, or advise on individual consumer credit decisions, creditworthiness determinations, or lending decisions. Outputs are for internal compliance gap analysis only. All inputs are processed entirely in-browser — no data is transmitted or stored.

Product Risk Profile

Define your BNPL product characteristics

Proportionality rules mean that the required depth of affordability assessment scales with product risk. Describe your product so the tool can calibrate the minimum required methodology depth.

Typical transaction value

Higher value → greater consumer harm potential → stricter assessment required.

Number of repayments

Longer repayment terms increase consumer risk exposure.

Product APR

Non-zero APR brings HCSTC or standard regulated credit rules into play.

Methodology Inventory

Which components does your affordability assessment include?

Answer for your standard BNPL product population. Use the MUST/SHOULD labels as a guide — MUST items are minimum regulatory requirements for at least one framework.

🇬🇧 FCA CONC 5

🇪🇺 EU CCD2 Art. 18

🇺🇸 CFPB ATR

Select at least one framework.

Income signal / verification method

MUST — FCA, CCD2, CFPB

FCA CONC 5.2A(2): must consider income and expenditure. Higher product risk requires stronger verification. [1]

Credit bureau / register data

MUST — CCD2 Art. 18(3) · CONC 5

CCD2 Art. 18(3): must consult credit register where available. [2]

Check existing financial commitments

MUST — FCA CONC 5.2A · CCD2

Assessment must consider existing credit commitments and total debt burden. [1]

Calculate net disposable income

MUST — FCA CONC 5.2A(2)(b)

Sustainable repayment must be assessed relative to income minus necessary expenditure. [1]

Apply repayment stress test

SHOULD — FCA Consumer Duty · CCD2

FCA Consumer Duty (PS22/9): consider foreseeable circumstances, including income volatility. [3]

Financial vulnerability screening

SHOULD — FCA Consumer Duty · CFPB UDAAP

FCA Consumer Duty requires identification of potentially vulnerable customers and adapted outcomes. [3]

Written methodology documentation

MUST — CCD2 Art. 18 · CONC 2.10

FCA CONC 2.10: maintain records of creditworthiness methodology. CCD2 Art. 18 requires documented basis. [2]

Periodic methodology review cycle

SHOULD — FCA CONC 2.10 · Consumer Duty

FCA Consumer Duty requires regular product/process review to confirm outcomes remain fair. [3]

Refusal / credit limit reduction for unaffordable cases

MUST — CCD2 Art. 18(4) · FCA CONC 5

CCD2 Art. 18(4): lender must decline or restrict credit when assessment indicates consumer cannot afford repayments. [2]

Consumer-facing affordability warning at checkout

SHOULD — FCA Consumer Duty · CCD2

Prompts such as "Only proceed if you can comfortably afford repayments" reduce consumer harm and support Consumer Duty outcomes. [3]

Unset boolean fields default to No.

Compliance Assessment

Affordability Methodology Assessment Results

Requirement Gap Table — Missing & Partial Items

Framework	Requirement	Type	Status	Remediation Action

Source Notes & Regulatory Citations

FCA CONC 5.2A — creditworthiness assessment for regulated consumer credit. CONC 5.2A(2): must assess ability to make repayments without undue difficulty, considering income and expenditure. CONC 5.2A(6): assessment must be proportionate to product risk. Applies to BNPL under new DPC regime from 15 July 2026 (FSMA 2023 Sch. 9). FCA CONC 2.10: records of creditworthiness assessment methodology must be maintained.
Directive 2023/2225/EU (CCD2), Art. 18 — creditworthiness assessment. Art. 18(1): creditor must conduct thorough assessment of creditworthiness before concluding agreement. Art. 18(3): creditor must consult credit register database where available. Art. 18(4): creditor must decline credit where assessment indicates consumer cannot afford repayments without significant financial difficulty. Transposition deadline: 20 November 2025.
FCA Consumer Duty (PS22/9) — effective July 2023, applying to BNPL distribution chains from July 2026. Outcome 4 (Financial resilience): firms must consider foreseeable circumstances including income volatility. PS22/9 Chapter 4: vulnerability identification is an expectation under the Consumer Duty, not optional. Regular product and process review required to confirm outcomes remain fair and sustainable.
CFPB BNPL Report (September 2022) — identified inadequate ability-to-repay assessment as a primary consumer harm risk in BNPL. CFPB Supervisory Highlights Spring 2023: cited insufficient creditworthiness verification in BNPL origination as UDAAP concern. 15 U.S.C. § 1638 (TILA): closed-end credit must include clear disclosure of credit terms before consummation. CFPB May 2024 interpretive rule: BNPL classified as credit cards with related consumer protections.
Proportionality analysis: product risk tier is derived from three inputs: transaction value, repayment count, APR. Low risk (under £50, ≤4 instalments, 0% APR) → lightweight assessment (soft signals + soft search sufficient). Medium risk → standard assessment (open banking or soft verification + soft search minimum). High risk (>£250, or any positive APR) → comprehensive assessment (open banking or hard verification + credit bureau required). Based on FCA CONC 5.2A(6) proportionality principle and FCA CP23/5 BNPL consultation data.
Scoring methodology: each requirement scored 1.0 (met), 0.5 (partially met), 0.0 (not met). MUST items carry weight 1.5; SHOULD items carry weight 0.75. Composite score = weighted sum / weighted maximum × 100. Tier: ≥80 Compliant, 60–79 Adequate, 40–59 Needs Improvement, <40 Non-Compliant. Client-side only. Zero PII.

BNPL Affordability Assessment Modeller