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Response to FCA Consultation: CP25/23: Deferred Payment Credit (unregulated Buy Now Pay Later): proposed approach to regulation

Anita Zhao Orcid Logo, Philippa Ward Orcid Logo, Ruffin Relja Orcid Logo

Research Report

Swansea University Author: Anita Zhao Orcid Logo

DOI (Published version): 10.23889/SUreport.70712

Abstract

This is a joint response from the UK’s leading DPC [colloquially termed Buy Now, Pay Later] research team, comprising academics from both Swansea University and the University of Gloucestershire, to the FCA consultation paper “CP25/23: Deferred Payment Credit (unregulated Buy Now Pay Later): propose...

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Published in: Research Report
Published: Swansea University 2025
URI: https://cronfa.swan.ac.uk/Record/cronfa70712
Abstract: This is a joint response from the UK’s leading DPC [colloquially termed Buy Now, Pay Later] research team, comprising academics from both Swansea University and the University of Gloucestershire, to the FCA consultation paper “CP25/23: Deferred Payment Credit (unregulated Buy Now Pay Later): proposed approach to regulation,” published in July 2025.While we are not legal experts, our role as marketing researchers allows us to offer valuable insights into the broader impacts of the proposed regulatory changes for both consumers and markets.We commend the FCA for recognizing the rapid expansion of the DPC sector and the potential risks it presents to consumer financial well-being, especially among vulnerable groups. The proposed approach to regulation addresses several key areas, such as transparency, affordability checks, and dispute resolution. However, additional considerations are needed to ensure that the regulation is effective, proportional, and future-proof. Specifically, we believe that three critical issues require further attention in the development of the DPC-specific rules, which we outline as part of our detailed response to your questions.
Keywords: Financial Conduct Authority (FCA), DPC (Deferred Payment Credit), Unregulated Buy Now Pay Later (BNPL), Legislation
College: Faculty of Humanities and Social Sciences
Funders: N/A

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