Determine whether your BNPL/Deferred Payment Credit product falls within the FCA regulatory perimeter under PS26/1 (effective 15 July 2026). Assess Temporary Permissions Regime (TPR) eligibility, and identify the correct authorisation pathway under the Consumer Credit Act 1974 and FSMA 2000.
In Force 15 Jul 2026PS26/1 · CP24/11TPR Window May 15 – Jul 1 2026Client-Side · Zero PII · CC BY 4.0
15 May – 1 Jul 2026TPR notification window — existing BNPL lenders● Notification window open
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Step 01Lender Type & Product Structure
Third-party lenders (e.g. Klarna, Clearpay) are the primary target of PS26/1. Merchants financing their own customers have a separate statutory exemption analysis.
PS26/1 targets specifically Deferred Payment Credit — interest-free credit repayable in ≤12 instalments or ≤12 months.
Step 02Repayment Terms & Product Parameters
DPC definition requires ≤12 instalments. 13+ moves product outside DPC scope (but may still be regulated under CCA).
DPC definition requires repayment within 12 months. Products > 12 months are outside DPC but may be regulated CCA fixed-sum loans.
DPC must be interest-free (excluding late payment fees). Any APR takes the product outside DPC and into regulated CCA territory.
Merchant own-book financing under s.12 CCA exemption may still apply, but PS26/1 removes most existing BNPL exemptions.
Step 03Authorisation Status & TPR Eligibility
Full CCA permission is required for DPC. Existing authorisation for other activities does not automatically cover DPC.
Existing BNPL lenders that notify FCA by 1 July 2026 may operate under TPR until full authorisation determined. TPR window: 15 May – 1 July 2026.
Volume affects proportionality considerations and FCA supervisory intensity. Limited permission route available for smaller operators.
Consumer Credit Act and PS26/1 apply to agreements with individuals (natural persons) acting for purposes outside their business. Pure B2B credit is outside CCA scope.
FCA DPC Scope & Authorisation Assessment
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Authorisation Pathway
Scope Determination Factors
Key Deadline & Action Table
Deadline
Action Required
Regulatory Basis
Status
AP2 v1.0 · @ainumbers.co/fca-dpc-scope-v1
Regulatory Sources
[1]FCA PS26/1: Policy Statement — Regulation of Buy Now Pay Later (Feb 2026). In force 15 July 2026.
[2]FCA CP24/11: Consultation Paper — Buy Now Pay Later (Jul 2024). Consumer Credit Act amendments and authorisation framework.
[3]Consumer Credit Act 1974 (as amended by Financial Services and Markets Act 2023, s.333A–333D). Deferred Payment Credit definition.
[4]Financial Services and Markets Act 2000 (Regulated Activities) Order 2001 (SI 2001/544), as amended. Specified activities: consumer credit, credit brokering.
[5]FCA: Temporary Permissions Regime for BNPL — notification window 15 May to 1 July 2026. FCA website: www.fca.org.uk/bnpl.