BNPL is regulated now. Your existing agreements are not.

On 15th July the Financial Conduct Authority began regulating Buy Now Pay Later. The coverage read like a finish line. Eleven million UK adults, a market worth around thirteen billion pounds, finally brought inside the rules. Money Saving Expert, Which? and most of the money pages ran the same headline: Buy Now Pay Later users are protected now.

Read the policy statement and the sentence changes. The protection is not attached to the user, the product, or the app on their phone; it is attached to a date. Only Deferred Payment Credit agreements entered into on or after 15th July 2026 are regulated (FCA PS26/1). Every agreement taken out before that date stays exactly where it was: unregulated, with no Section 75 cover and no route to the Financial Ombudsman.

That is not a footnote. Buy Now Pay Later is short-dated credit by design, most of it interest-free and repaid in three or four instalments over a few weeks (FCA PS26/1 defines it as credit repayable in twelve or fewer instalments over twelve months or less). The balances people are carrying today were, overwhelmingly, opened before 15th July. So on the morning the protections went live, they applied to almost none of the money actually outstanding.

The new regime, when it does apply, is worth having. An agreement caught by it comes with proportionate affordability checks, clearer information up front, consistent credit reporting, and two things that matter when a purchase goes wrong. Section 75 of the Consumer Credit Act 1974 makes the lender jointly liable with the retailer on anything costing between one hundred and thirty thousand pounds. And access to the Financial Ombudsman means someone can force the issue if the lender will not put it right. Those are the same rails a credit card gives you. For a product that until this month gave you neither, that is a real upgrade.

There is a second line in the rules the headlines skipped. Deferred Payment Credit is only regulated where the lender and the shop are different businesses (FCA PS26/1). Third-party Buy Now Pay Later, Klarna, Clearpay, Zilch, is caught. Where a retailer runs its own instalment plan on its own paper, it is not. Two people can buy the same sofa on the same day, both on Buy Now Pay Later, and only one of them ends up with an ombudsman behind them.

For anyone with a Buy Now Pay Later dispute right now, this collapses into two questions asked before anything else. When did you enter the agreement? And is the lender a different company from the shop? Those two answers decide which rulebook you are in. The first question I ask on any dispute that involves credit is when the agreement was signed, not what went wrong, because the date usually decides the remedy before the facts do.

If the agreement is dated 15th July or later and a third party lent the money, you are on the good rails. Complain to the lender, quote Section 75 for anything over a hundred pounds, and if you get nowhere, escalate to the Financial Ombudsman.

If the agreement is older, or the shop financed it itself, none of that is there and you fight the case on the ground that has always existed. The retailer still owes you the Consumer Rights Act 2015: goods of satisfactory quality (section 9), the thirty-day right to reject faulty goods (section 22). The card you pay the instalments from still gives you a chargeback through your bank. The provider still has to run a complaints process, it just does not have the ombudsman standing behind it. That is a weaker hand, but it is not no hand, and the mistake is to assume a new regime rescues a dispute it was never written to touch.

The through-line is worth keeping past this particular story. Consumer protection almost never switches on for a person or a product. It switches on for a transaction with the right shape, on the right side of a date, structured the right way. The work in any dispute is figuring out which transaction you actually have, not which headline was written about it. Eleven million people were told this week that they were covered. A good number of them are, from their next purchase. On the balance already sitting in the app, they are exactly as covered as they were on 14th July, which is to say not at all.

Check the date on the agreement before you check anything else.

Also worth your time this week

The week the rules caught up with Buy Now Pay Later, and a reminder to read the small print on when they actually start.

• Buy Now Pay Later came under FCA regulation on 15th July. Affordability checks, Section 75 cover and Financial Ombudsman access now apply, but only to agreements taken out on or after that date. Existing balances stay unregulated. FCA PS26/1.
• The money pages all covered it. Money Saving Expert's explainer is the clearest on the "new agreements only" catch, and flags the free ombudsman route. MoneySavingExpert.
• Which? ran its own version, framed around faster refunds and what to do when a Buy Now Pay Later purchase goes wrong. Which?.
• The FCA's joint taskforce escalated its crackdown on misleading car finance claims adverts. 170 more adverts pulled or amended in June, around 1,200 since January 2024, plus consumer alerts against eight unauthorised firms and two enforcement investigations. Complaining directly to your lender is free. FCA.
• The CMA opened a formal investigation into Euro Car Parks' appeals process and put the private parking industry on notice, with a strengthened Code of Practice on the way. Worth knowing the difference between a private parking charge and a council penalty. Resolver.
• The FCA urged customers of insurance broker Anthony Jones (UK) Limited to check their cover after the firm stopped all regulated activity on 9th July. Contact your insurer directly to confirm the policy is still in force. FCA.
• Two OPSS product safety reports landed this week: several water bead products sold via Amazon UK, an asphyxiation risk to young children, and a JOYHUT life jacket rejected at the border for lacking safety documentation. OPSS recalls.
• The Financial Ombudsman decisions database is running on its usual publication lag. The most recent decision now visible is dated 2nd June, up from 21st May a week ago, so the queue is moving, just slowly.

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