UK BNPL and Deferred Payment Credit compliance, FCA authorisation and TPR support
UK BNPL (DPC) Regulation: FCA Authorisation & TPR Support
If you offer Buy Now Pay Later (now termed Deferred Payment Credit, or DPC), UK regulation is arriving on 15 July 2026. From that date, in-scope third-party DPC lenders must be authorised by the FCA or operate under a Temporary Permissions Regime (TPR). Agreements made before Regulation Day remain exempt, and broking of DPC is out of scope. Alumni Compliance helps existing providers and new entrants navigate this change with a clear plan and complete delivery.
If you offer Buy Now Pay Later (now termed Deferred Payment Credit, or DPC), UK regulation is arriving on 15 July 2026. From that date, in-scope third-party DPC lenders must be authorised by the FCA or operate under a Temporary Permissions Regime (TPR). Agreements made before Regulation Day remain exempt, and broking of DPC is out of scope. Alumni Compliance helps existing providers and new entrants navigate this change with a clear plan and complete delivery.
Overview of the regime
The Government has legislated to bring third-party DPC into the FCA perimeter. The FCA’s timetable runs from consultation and final rules in early 2026 to go-live on 15 July 2026. From go-live, lenders entering new DPC agreements must either hold permission via the TPR or already be fully authorised for the relevant consumer credit activities. This change brings BNPL standards into line with broader consumer credit expectations, including affordability, arrears handling, forbearance, and Consumer Duty.
Existing BNPL firms: use the TPR
If your business was carrying on DPC lending on 15 July 2025, you may register for the FCA’s Temporary Permissions Regime. The notification window opens two months before Regulation Day and closes two weeks before. Registration requires a notification to the FCA, payment of the fee, and evidence that you were active on 15 July 2025. Under the TPR you can continue lending on and after Regulation Day while you prepare and submit a full authorisation application.
Alumni Compliance runs the process for you. We confirm eligibility, assemble the evidence pack demonstrating activity on 15 July 2025, prepare and file the TPR notification in the window, and then deliver the full authorisation application within the post-go-live six-month period. Our team drafts a robust, model-specific regulatory business plan, implements Consumer Duty-ready policies and controls, maps senior managers and governance, and liaises directly with FCA authorisations case officers to resolution.
New entrants and international launches: full authorisation
Firms that were not lending on 15 July 2025 cannot use the TPR. In these cases, you must be authorised before entering regulated DPC agreements from 15 July 2026. Alumni Compliance provides an end-to-end authorisation programme: we scope permissions, design the target operating model and oversight, prepare financials and wind-down analysis, build day-one policies and MI, submit via FCA Connect, and manage all queries through to a decision. This pathway positions you to launch on or after Regulation Day without relying on temporary permissions.
Why act now
The TPR window is short, and evidence of trading on 15 July 2025 must be gathered and presented clearly. Even if you will not use the TPR, aligning your business plan, policies and controls to the FCA’s materials ahead of the final rules reduces rework and de-risks authorisation timelines. Early preparation also supports board governance, fair value assessments, and product communication changes required under Consumer Duty.
What Alumni Compliance delivers
You get a single accountable team that scopes your permissions, drafts the regulatory business plan, and builds a tailored policy framework covering creditworthiness and affordability, arrears and forbearance, vulnerable customers, complaints and FOS handling, financial promotions, governance, reporting and MI. We complete senior managers and governance mapping, prepare conduct risk and Consumer Duty frameworks, and act as your point of contact with FCA case officers. Our approach is practical and time-bound so your team can focus on customers while we handle regulatory delivery.
Frequently asked questions
From 15 July 2026, third-party DPC agreements become regulated credit. Lenders must be authorised or in the TPR and comply with FCA rules. Agreements entered before Regulation Day remain exempt.
Firms that were carrying on DPC lending on 15 July 2025 and that notify the FCA during the published window, pay the fee, and provide evidence of activity on that date.
Within six months after 15 July 2026. Continuing to rely on temporary permission without submitting a complete application within that period is not permitted.
Get started
Whether you need a rapid TPR registration followed by a complete authorisation application, or a full new-entrant authorisation from scratch, Alumni Compliance delivers BNPL/DPC regulatory readiness at pace. Contact us for a short scoping call, fixed-fee options, and a delivery plan aligned to the FCA’s dates.