UK FCA BNPL rules from 15 July 2026 expose transaction-level gaps in acquiring and processing

The Financial Conduct Authority’s new Buy Now Pay Later rules are not just a consumer-credit story. For acquirers and processors, the real issue is whether their systems can distinguish regulated from unregulated Deferred Payment Credit (DPC) at the individual transaction level, with Section 75 liability, reporting, and dispute handling now attached to the answer.

1. New FCA rules governing BNPL came into force on 15 July 2026, bringing UK BNPL into the mainstream consumer credit regime and requiring providers of Deferred Payment Credit agreements to conduct affordability checks.
2. Robert Kraal, co-founder of Silverflow and former chief operating officer at Adyen, says the harder problem sits inside acquiring and processing infrastructure: under the new framework, whether a DPC agreement is regulated depends on the lender-merchant relationship and the date the agreement was signed.
3. That means regulated and unregulated BNPL payments will continue to move on the same processing rails, but acquirers now have to distinguish between them transaction by transaction rather than by product category. As Kraal put it, if an acquirer or processor does not have that information, it cannot be compliant.
4. Kraal said acquirers and processors must also account for new Section 75 refund exposure and support the dispute, reporting, and consumer duty obligations that follow. Under the Consumer Credit Act, Section 75 gives consumers a claim against the creditor as well as the merchant in the event of breach of contract or misrepresentation.
5. The broader problem is a familiar one in payments: many legacy processing platforms were built to move money efficiently, not to tag, trace, and report transactions at the resolution modern regulation now assumes. Several established processors are still in multi-year core platform modernisation programmes, and the BNPL rules arrive before those programmes are complete.

The FCA’s move follows years of consultation and multiple missed legislative windows since the Woolard Review, but for PSPs the practical test is more basic: can the stack separate regulated from unregulated DPC in real time, or does the compliance work get pushed into manual reconciliation after the fact?