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Response to FCA Consultation CP26/15: CONC 3: Reviewing the Financial Promotions Rules for Consumer Credit
Anita Zhao 
,
Ruffin Relja ,
Philippa Ward
,
Ruffin Relja ,
Philippa Ward
Research Report
Swansea University Author:
Anita Zhao
DOI (Published version): 10.23889/SUreport.72104
Abstract
We welcome the opportunity to respond to CP26/15. We write as academic researchersspecialising in consumer behaviour, financial decision-making, and Deferred Payment Credit(DPC)/Buy-Now-Pay-Later (BNPL). Our work draws on extensive mixed-methods researchwith UK consumers and on stakeholder engagemen...
| Published in: | Research Report |
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| Published: |
Swansea University
2026
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| URI: | https://cronfa.swan.ac.uk/Record/cronfa72104 |
| Abstract: |
We welcome the opportunity to respond to CP26/15. We write as academic researchersspecialising in consumer behaviour, financial decision-making, and Deferred Payment Credit(DPC)/Buy-Now-Pay-Later (BNPL). Our work draws on extensive mixed-methods researchwith UK consumers and on stakeholder engagement across the BNPL ecosystem.Consistent with our previous consultation responses, we strongly support the FCA’s objectiveof balancing consumer protection, innovation, and proportionality.However, our research demonstrates that credit, particularly DPC/BNPL, is not simply afinancial product. It is embedded within retail environments, digital interfaces, and algorithmicmarketing systems that actively shape consumer behaviour. Financial promotions, therefore,are not neutral disclosures, but integral components of consumption systems. |
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| College: |
Faculty of Humanities and Social Sciences |
| Funders: |
None |