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FCA secures contract charges for BNPL customers

What has happened? 

In October 2023, the FCA announced that it had agreed deals with two buy now pay later (BNPL) firms, PayPal and QVC, to make their contract terms easier to understand for borrowers and ensure consumer credit compliance.

What is the background and key points of the announcement?

These deals with BNPL firms were made at a time when published FCA research based on the regulator’s Financial Lives survey showed that 27% of UK adults (approximately 14 million) have used BNPL (also termed Deferred Payment Credit) at least once in the six months prior to January 2023. This is up from 17% who said they had used it in the preceding 12 months in May 2022.  The research also points out that;

…That [Deferred Payment Credit] is more likely to be used, and used more frequently, by people with characteristics of vulnerability makes it all the more important that providers understand how and why their customers are using it, and whether they are offering an appropriate product given the specific needs and challenges of their customer base. This is a key requirement under the Consumer Duty.

In this instance, the FCA used its powers under the Consumer Rights Act 2015 to secure changes to potentially unfair and unclear contract terms in this sector, building on the FCA’s work with other BNPL providers last year and the guidance issued at the time.

The FCA does not yet have regulatory oversight over BNPL products but it worked with PayPal and QVC to voluntarily make their continuous payment authority terms easier to understand. PayPal has also made terms relating to what happens when a consumer cancels the purchase funded by the loan clearer and fairer.

How can we help you with consumer credit compliance? 

Thistle Initiatives has supported credit firms for over 10 years as a trusted consumer credit compliance and regulatory advisor. In addition to assisting you as-and-when, our team of specialists can serve as your right hand in meeting and complying with FCA regulations. We understand the importance of staying up-to-date and compliant and are dedicated to providing the guidance and support needed to do so.

Are you looking for help with your BNPL arrangements, vulnerable customer or Consumer Duty approach, or more general regulatory questions? Contact our specialist team now to schedule a free consultation. Get in touch with us by calling 020 7436 0630 or sending an email to

See also our BNPL blog posts at  Lenders offering Buy-Now Pay-Later (BNPL) and related products to be FCA regulated ( and Making Buy Now Pay Later terms clearer and fairer (