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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
first_indexed 2025-10-17T08:58:24Z
last_indexed 2025-12-05T18:10:17Z
id cronfa70712
recordtype SURis
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spelling 2025-12-04T11:55:42.6754114 v2 70712 2025-10-17 Response to FCA Consultation: CP25/23: Deferred Payment Credit (unregulated Buy Now Pay Later): proposed approach to regulation ea60dfdee64a02b6d5536c75f2575a00 0000-0003-2957-8300 Anita Zhao Anita Zhao true false 2025-10-17 CBAE 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. ResearchReportExternalBody Research Report Swansea University Financial Conduct Authority (FCA), DPC (Deferred Payment Credit), Unregulated Buy Now Pay Later (BNPL), Legislation 25 10 2025 2025-10-25 10.23889/SUreport.70712 COLLEGE NANME Management School COLLEGE CODE CBAE Swansea University Not Required N/A 2025-12-04T11:55:42.6754114 2025-10-17T09:47:02.0268811 Faculty of Humanities and Social Sciences School of Management - Business Management Anita Zhao 0000-0003-2957-8300 1 Philippa Ward https://orcid.org/0000-0002-4971-8908 2 Ruffin Relja https://orcid.org/0000-0001-9569-6247 3 70712__35408__55578af4741b4c4fa50d84e295736e24.pdf 70712.pdf 2025-10-20T14:25:49.7428207 Output 240736 application/pdf Version of Record true 2025-10-25T00:00:00.0000000 Copyright, The Authors, 2025. true eng
title Response to FCA Consultation: CP25/23: Deferred Payment Credit (unregulated Buy Now Pay Later): proposed approach to regulation
spellingShingle Response to FCA Consultation: CP25/23: Deferred Payment Credit (unregulated Buy Now Pay Later): proposed approach to regulation
Anita Zhao
title_short Response to FCA Consultation: CP25/23: Deferred Payment Credit (unregulated Buy Now Pay Later): proposed approach to regulation
title_full Response to FCA Consultation: CP25/23: Deferred Payment Credit (unregulated Buy Now Pay Later): proposed approach to regulation
title_fullStr Response to FCA Consultation: CP25/23: Deferred Payment Credit (unregulated Buy Now Pay Later): proposed approach to regulation
title_full_unstemmed Response to FCA Consultation: CP25/23: Deferred Payment Credit (unregulated Buy Now Pay Later): proposed approach to regulation
title_sort Response to FCA Consultation: CP25/23: Deferred Payment Credit (unregulated Buy Now Pay Later): proposed approach to regulation
author_id_str_mv ea60dfdee64a02b6d5536c75f2575a00
author_id_fullname_str_mv ea60dfdee64a02b6d5536c75f2575a00_***_Anita Zhao
author Anita Zhao
author2 Anita Zhao
Philippa Ward
Ruffin Relja
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institution Swansea University
doi_str_mv 10.23889/SUreport.70712
college_str Faculty of Humanities and Social Sciences
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hierarchy_top_title Faculty of Humanities and Social Sciences
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hierarchy_parent_title Faculty of Humanities and Social Sciences
department_str School of Management - Business Management{{{_:::_}}}Faculty of Humanities and Social Sciences{{{_:::_}}}School of Management - Business Management
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description 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.
published_date 2025-10-25T05:31:29Z
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