What it means for youBorrowing & credit
Using buy now, pay later for Black Friday or Christmas? The protections you now have, and the gaps
Since 15 July 2026, most buy now, pay later deals from separate lenders are regulated by the Financial Conduct Authority. That brings affordability checks, clearer information and a free route to complain. Some plans are still not covered.
Published 1 November 2026Last checked 1 November 2026UK-wideFrom Financial Conduct Authority
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What's happening
Buy now, pay later (BNPL) lets you split a purchase into interest-free payments. Since 15 July 2026, plans from a lender that is separate from the shop are regulated by the Financial Conduct Authority (FCA). Lenders must check you can afford it, explain the payments and late fees before you sign, help you if you struggle, and you can take complaints to the Financial Ombudsman for free.
The question: What protections do you get when you use buy now, pay later, and which plans are still outside the rules?
The policy
- Announced by
- Financial Conduct Authority (rules); HM Treasury (law)
- Announced on
- 2026-02-11
- Stage
- in force
- Takes effect
- 2026-07-15
- Shopper splitting a £300 TV with a separate BNPL lender in November 2026: Gets an affordability check, clear information on payments and late fees, a possible Section 75 refund if the TV is faulty, and access to the Financial Ombudsman.
- Shopper using a shop's own pay-in-instalments offer: None of the new FCA protections apply. Normal consumer rights against the shop still do.
- Someone still paying off a BNPL plan taken out in May 2026: That plan stays unregulated. Any new plan from 15 July 2026 is covered.
This applies to you if…
- You agreed the plan on or after 15 July 2026
- The lender is a different business from the shop (a third-party lender)
- The plan is interest-free and paid back in 12 or fewer instalments within 12 months
Not for you if…
- Plans agreed before 15 July 2026, which stay unregulated
- A shop's own instalment plan, where the shop itself lends you the money
- Plans that charge interest, which are covered by other credit rules
What it's worth
FCA rules in force from 15 July 2026; Section 75 of the Consumer Credit Act 1974 covers single items with a cash price over £100 and up to £30,000.
How to do it
- 1
At checkout, look at who the BNPL agreement is with. If it is a separate lender, the new rules apply to plans agreed from 15 July 2026.
- 2
Check the lender is allowed to lend
Search the FCA Firm Checker. Look for 'Authorised' with permission for unsecured lending, or a listing on the temporary permission register.
Takes about 2 minutes
- 3
Read the information before you agree
The lender must tell you how much you're borrowing, when each payment is due and how much it is, any late fee, and your rights.
- 4
If something goes wrong with your purchase
Contact the shop first. If that fails and the item cost over £100, you can ask the BNPL lender for a refund under Section 75.
- 5
If you can't keep up the payments
Tell the lender early. They must support you and point you to free debt advice where appropriate.
- 6
If the lender won't sort it out
Complain to the lender first. If you're unhappy with the answer, or after 8 weeks, you can go to the Financial Ombudsman for free.
Deadline
Black Friday is Friday 27 November — 27 November 2026 (in 26 days)
Only plans agreed on or after 15 July 2026 get the new protections.
The catches
Shops' own plans are still unregulated
If the shop lends you the money itself, the new rules don't apply. The FCA says this kind of plan remains exempt.
Older plans aren't covered
Plans taken out before 15 July 2026 stay unregulated, so the Ombudsman can't look at complaints about them.
Late fees can still apply
Interest-free doesn't mean fee-free. The FCA expects late fees to be no higher than needed to cover reasonable costs, and the lender must show the fee before you agree.
It may show on your credit file
The rules don't make lenders report to credit reference agencies, but many do. Missed payments could appear on your credit file, depending on the lender.
Section 75 has limits
It covers single items costing more than £100 and up to £30,000. Citizens Advice says it usually doesn't apply if you pay through a third party such as PayPal.
Illustrative example
A faulty coat bought with BNPL
In late November, Jo buys a £160 winter coat online and splits it into four payments of £40 with a separate BNPL lender.
- The coat arrives with a broken zip.
- Jo contacts the shop within 30 days and asks for a refund for faulty goods.
- The shop doesn't reply.
- Because the coat cost over £100 and the plan started after 15 July 2026, Jo asks the BNPL lender for a refund under Section 75.
- If the lender refuses, Jo can take a complaint to the Financial Ombudsman for free.
Jo has two routes to get her money back: the shop, then the lender.
Illustrative example. Whether a Section 75 claim succeeds depends on the facts.
What this means for…
- Borrowing or in debt: Lenders must now check affordability and support you if you struggle. Free debt advice is available.
- 25–54: FCA research found people aged 25 to 34 were among the most likely to use BNPL, at 30%.
- Under 25: A new BNPL plan from a separate lender now comes with an affordability check and clear late-fee information.
Common misreadings
You might hear: All buy now, pay later is now regulated.
Actually: Only plans from a separate lender, agreed on or after 15 July 2026. A shop's own plan and older plans aren't covered.
You might hear: Interest-free means there's no cost if you pay late.
Actually: Lenders can charge late fees. They must tell you the amount before you agree, and missed payments could be reported on your credit file.
You might hear: You can't get your money back if you paid with BNPL.
Actually: For regulated plans, the FCA says Section 75 may give you a refund if something goes wrong, the same protection as a credit card, for items over £100.
Where the UK nations differ
- UK-wide
- The FCA rules and the law behind them apply in England, Wales, Scotland and Northern Ireland.
- Northern Ireland
- For shopping problems, Consumerline gives advice instead of Citizens Advice consumer service. National Debtline covers England, Wales and Scotland. StepChange and MoneyHelper also give free debt help.
- Scotland
- You usually have 5 years to make a claim about faulty goods, compared with 6 years in the rest of the UK.
What you could do
are about to use BNPL for Black Friday or Christmas shopping
By 2026-11-27
bought something over £100 with BNPL since 15 July 2026 and it's faulty or never arrived
are finding BNPL payments hard to keep up with
Timeline
11 February 2026
FCA confirms the rules
15 July 2026
Rules come into force
Applies to plans agreed on or after this date.
27 November 2026
Black Friday
The detail
The rules
- Deferred payment credit means interest-free credit repaid in 12 or fewer instalments within 12 months.
- Covered: plans where the lender and the seller are different businesses, agreed on or after 15 July 2026.
- Lenders must make proportionate affordability checks before lending.
- Before you agree, lenders must show the amount borrowed, when each payment is due and how much, any late fee, and your rights.
- Lenders must tell you if you miss a payment and what it means.
- Firms that registered under the temporary permission regime have 6 months to apply for full authorisation.
- Separately, for most online purchases you have 14 days to cancel, starting the day after delivery, then 14 days to send the item back. The seller must refund you within 14 days (Citizens Advice).
- Faulty goods: you have 30 days to reject them for a full refund (Consumer Rights Act 2015).
References
- FCA policy statement PS26/1: Final rules for deferred payment credit; agreements made before Regulation Day stay unregulated.
- Consumer Credit Act 1974, section 75: The lender shares responsibility for the seller's breach of contract or misrepresentation, for single items over £100 and up to £30,000.
- Consumer Rights Act 2015, section 22: 30-day short-term right to reject faulty goods.
Words explained
- Buy now, pay later (BNPL)
- Splitting the cost of something into interest-free payments, usually over a few weeks or months.
- Deferred payment credit
- The legal name for the kind of BNPL that's now regulated.
- Third-party lender
- A finance company that's separate from the shop you're buying from.
- Section 75
- A law that can make a lender share responsibility with a seller when something goes wrong, for items over £100.
- Financial Ombudsman Service
- A free, independent service that settles complaints between people and financial firms.
In short
If you use buy now, pay later from a separate lender, plans agreed since 15 July 2026 come with affordability checks, clear late-fee information and free complaints to the Financial Ombudsman. A shop's own plans and older plans aren't covered, and late payments can still cost you.
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Sources
- New protections confirmed for Buy Now Pay Later borrowers, FCA (2026-02-11)
- Buy now pay later, FCA (2026-11-01)
- PS26/1: Regulation of deferred payment credit, FCA (2026-02-11)
- Protections to help buy now pay later borrowers, FCA (2025-07-18)
- Regulation of Buy Now, Pay Later: consultation response, HM Treasury (2025-05-16)
- Goods and services bought on credit, Financial Ombudsman Service (2026-11-01)
- Consumer Credit Act 1974, section 75, legislation.gov.uk
- Changing your mind about something you've bought, Citizens Advice (2026-11-01)
- Getting your money back if you paid by card or PayPal, Citizens Advice (2026-11-01)
- Accepting returns and giving refunds, GOV.UK (2026-11-01)
This is guidance, not regulated financial advice. Check figures against the linked official source before you act. Written with AI assistance and checked against primary sources. How Kitty works. For free, impartial help, try MoneyHelper or Citizens Advice.