UK BNPL and Deferred Payment Credit compliance, FCA Authorisation and TPR support
FCA Deferred Payment Credit Regulation: Guidance for Firms
Deferred Payment Credit (DPC) FCA regulation is bringing certain third-party lender DPC models into the UK consumer credit regulatory regime. If your firm is a DPC lender (or operates a DPC model involving a merchant and a third-party lender), you may need the relevant consumer credit permissions or a temporary permission under the DPC Temporary Permissions Regime (TPR) from regulation day.
Who This Applies To
DPC agreements provided by third-party lenders will become regulated credit agreements where (1) the lender and the supplier of goods or services are not the same person, and; (2) there is an arrangement between a merchant and a lender so that the lender becomes the legal supplier of goods and services to the customer.
Where third-party lender DPC will not be regulated
DPC agreements provided by third-party lenders will not be regulated where they are:
(1) used to finance premiums under contracts of insurance;
(2) funding employee borrowing;
(3) provided by registered social landlords to their tenants, leaseholders or (in Scotland) the shared owner under a shared ownership agreement to finance goods and services;
(4) entered into before regulation day.
The Government has also decided that broking of DPC agreements will be exempt from regulation.
Our team drafts a robust, model-specific Regulatory Business Plan (RBP), builds Consumer Duty-ready policies, procedures and controls, maps SMCR governance and senior manager responsibilities, and manages application correspondence through FCA Connect—including responding to authorisations case officer queries clearly, promptly and with the supporting evidence needed to progress the application.
What firms need to do
From regulation day onwards, any DPC lender entering into a DPC agreement will need be authorised for the relevant consumer credit activities, or hold a temporary permission under the DPC TPR, complying with FCA rules throughout. Any DPC agreements entered into before regulation day will remain exempt.
If your firm does not currently hold the relevant consumer credit permissions, you will be able to enter the TPR. The TPR will allow you to continue operating on and after regulation day while the FCA considers your application for the necessary permissions.
If you choose not to enter the TPR, you must stop any DPC activities that will be subject to regulation by regulation day.
Firms that are not authorised (and do not have a temporary permission) will continue to be able to service DPC agreements taken out before regulation day, as those agreements will remain exempt.
Entering the DPC Temporary Permissions Regime
To enter the TPR, you will need to notify the FCA. Your firm will only be able to enter the TPR where it meets all the following criteria:
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You were carrying on a DPC activity on 15 July 2025
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You have notified the FCA before regulation day
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You have paid the relevant registration fee (to be consulted on in a future consultation)
You will be able to submit a TPR notification 2 months before regulation day. Notification for registration for the TPR will close 2 weeks before regulation day. The FCA will publish more information, including the dates on which the notification period will open and close, in due course. When notifying the FCA, you will need to provide:
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Evidence that you were carrying on DPC lending on 15 July 2025
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Your firm’s details, including registered office, principal place of business and any trading names
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Details of your firm’s controllers and senior manager.
How Alumni Compliance can help
Alumni Compliance helps firms prepare for FCA Deferred Payment Credit regulation by providing clear, practical support aligned to the new regulatory perimeter. We start by assessing your DPC structure to confirm whether your model will become a regulated activity and where any exemptions apply. We then map the most appropriate route to compliance, including TPR readiness and a permissions strategy that reflects how your DPC proposition operates in practice.
To support implementation, we help you plan for the operational changes implied by the FCA’s objectives—ensuring your customer information supports effective decision-making, your approach to responsible lending and affordability is credible, and you have appropriate arrangements to support customers in financial difficulty. We also organise the core information typically needed for a DPC TPR notification, including your firm’s details and trading names, details of controllers and senior managers, and the evidence demonstrating DPC activity on 15 July 2025.
Contact Alumni Compliance to discuss how DPC regulation may affect your business model and what you should prioritise before regulation day.