Retailers often offer to split the cost of a travel system or pushchair into instalments at checkout. Until recently, the interest-free kind of “Buy Now Pay Later” was largely unregulated. This guide explains what the Financial Conduct Authority (FCA) says changed on 15 July 2026, what still falls outside the rules and what to check at the checkout. It applies across the UK and is general information, not financial advice.
What was regulated on 15 July 2026
The FCA says it started regulating Deferred Payment Credit, often known as Buy Now Pay Later, on 15 July 2026. It describes two types of Buy Now Pay Later: one that charges interest, or charges interest if the customer does not repay within a set time, and Deferred Payment Credit (DPC), which is an interest-free form of credit repayable in 12 or fewer instalments over 12 months or less. Before 15 July 2026, DPC agreements were not regulated, so lenders did not need to be authorised by the FCA or follow its rules (FCA, “Buy Now Pay Later”).
The FCA’s press release explains that “BNPL” is a broad term that can include credit agreements that were already regulated, and that the new final rules cover the previously unregulated agreements, which legislation calls deferred payment credit (FCA, “New protections confirmed for Buy Now Pay Later borrowers”).
What lenders now have to do
According to the FCA, lenders must follow its rules for DPC from 15 July 2026. The FCA lists these protections:
- Affordability: lenders need to check whether the customer can afford to repay before an agreement is taken out. The press release describes the checks as proportionate.
- Information: lenders must give key information beforehand, including the amount borrowed, when repayments are due, how much they will be, how much any late fee will be, and the rights and protections the customer has.
- Support: lenders must provide support to customers who are struggling to repay, and where appropriate, direct them to free debt advice.
- Complaints: a customer unhappy with a lender should first ask the lender to put things right, and can then complain to the Financial Ombudsman Service.
The FCA’s press release adds that BNPL is subject to the Consumer Duty and that lenders need to be authorised by the FCA to provide it.
What is not regulated
The new protections have limits, and the FCA sets them out:
- DPC is regulated where the lender and the supplier of the goods are different businesses. If a buyer uses DPC provided by the same business that sells the item, it is not regulated. The FCA’s press release describes this as the exemption for “merchant own credit”, a decision the Government made in 2024.
- Any DPC agreement taken out before 15 July 2026 remains unregulated, and the new protections do not apply to it.
For a pram buyer, this means that the same checkout button can lead to different legal positions. A pushchair paid for through a third-party lender is within the regime, whereas a retailer’s own instalment plan is not. Which applies depends on who the lender is.
Checking the lender is authorised
The FCA advises checking a DPC lender on its Firm Checker. The steps are to search for the firm by name, select the service “Borrowing money, including credit card lending and credit information”, and confirm the firm is “Authorised” with permission to “Lend you money on an unsecured basis”. If a lender is not yet authorised, it may still be able to offer DPC under the FCA’s temporary permissions regime, and the FCA publishes a register of those lenders. A lender in that regime must follow the FCA’s rules for agreements made from 15 July.
Section 75 and refunds
The FCA states that if something goes wrong with goods bought using DPC, the customer may be able to get a refund from the lender, because Section 75 of the Consumer Credit Act is available, the same protection as when paying by credit card. Our guide to paying for a pram by card explains how Section 75 works and where its limits lie. A buyer with a faulty pushchair still has rights against the retailer as well, as set out in our guide to faulty pushchairs.
What to look at before choosing instalments
- The total price: compare the instalment total with the cash price, remembering that delivery must be included in the advertised price, as covered in our guide to advertised pram prices.
- Late fees: the FCA says lenders must now state how much any late fee will be, so it is possible to see the cost of a missed instalment in advance.
- Affordability: the FCA reminds consumers that BNPL is borrowing, and that they should make sure they can afford the repayments.
- Help: anyone struggling with money can get guidance from MoneyHelper, and use its Debt Advice Locator tool to find free services.
Questions readers often ask
Is a pram bought on interest-free instalments now protected?
If the lender is a different business from the seller and the agreement began on or after 15 July 2026, the FCA says it falls within the regulation.
Can a buyer still cancel the order?
The right to cancel an online order is a separate matter, covered in our guide to the 14-day cancellation right.
The bottom line
Since 15 July 2026, the FCA has regulated interest-free Buy Now Pay Later (deferred payment credit) when the lender and the seller are different businesses. Lenders must check affordability, give clear information, support customers in difficulty and accept complaints that can go to the Financial Ombudsman Service, and Section 75 refund protection is available. A retailer’s own instalment plan and any agreement made before that date remain outside the new rules, so checking who the lender is comes first.