News

BNPL: UK government lays SI exempting domestic premises suppliers from BNPL credit broking rules

05 November 2025

On 4 November 2025, the government laid the Financial Services and Markets Act 2000 (Regulated Activities etc.) (Amendment) (No. 2) Order 2025 (Amendment Order), introducing an exemption for domestic premises suppliers from the requirement to hold credit broking permissions when offering buy now, pay later (BNPL) products under the new regime coming into effect from 15 July 2026.

The Amendment Order follows a June 2025 HMT policy paper that confirmed domestic premises suppliers would be exempt from the requirement to hold credit broking permissions when offering BNPL products. The policy update resulted from further engagement with the FCA and industry stakeholders after the government’s BNPL consultation response in May 2025. The exemption addresses concerns that requiring in-home sellers to seek FCA authorisation would place a disproportionate burden on small businesses and limit consumer access to interest-free credit for low-value purchases.

The new BNPL regime introduced by the Financial Services and Markets Act 2000 (Regulated Activities etc) (Amendment) Order 2025 (as amended by the Amendment Order) will take effect from 15 July 2026, with a Temporary Permissions Regime in place for those firms who don't currently hold the necessary permissions.

An FCA consultation on detailed rules for regulated BNPL firms closed on 26 September 2025. A policy statement with final rules is due in early 2026. Take a look at this Our Thinking article for more on the consultation.

If you would like to discuss any aspect of the new BNPL regime, please feel free to get in touch with any of the people listed above or your usual Hogan Lovells contact.

Authored by Virginia Montgomery.