FCA Regulatory Update: PS26/1: Regulation of Deferred Payment Credit (unregulated Buy Now Pay Later)

Executive Summary

This update summarises key FCA developments and what they mean in practice for regulated firms.

Top source items by relative impact score.

PS26/1: Regulation of Deferred Payment Credit (unregulated Buy Now ... 95 CP26/1: The Value for Money Framework: Response to consultation, fu... 90 CP25/30: Streamlining the UK EMIR Intragroup Regime 90 CP25/2: Proposed changes to MiFID conduct of business rules for ret... 85 CP26/5: Aligning listed issuers’ sustainability disclosures with in... 83

Higher bars indicate higher relative operational or compliance impact.

Key FCA Developments

• PS26/1: Regulation of Deferred Payment Credit (unregulated Buy Now Pay Later)
  Our final rules on the regulation of Deferred Payment Credit (DPC) will ensure that DPC borrowers have appropriate protections when using the product. ... Read PS26/1 (PDF)What we are changing DPC has been more commonly known as Buy Now Pay Later (BNPL).DPC refers to an interest-free credit product,
  Source update
• CP26/1: The Value for Money Framework: Response to consultation, further consultation and discussion paper
  The Value for Money (VFM) Framework is intended to support a significant shift in the way the workplace pensions industry operates and competes. This document contains our updated proposals, reflecting feedback from the previous FCA consultation (CP24/16). ... Read CP26/1 (PDF)Why we are consulting
  Source update
• CP25/30: Streamlining the UK EMIR Intragroup Regime
  Read our proposals to make the UK EMIR Intragroup Regime clearer for counterparties seeking intragroup exemptions from clearing and margin requirements. ... Read CP25/30Why we are consultingThe Temporary Intragroup Exemption Regime (TIGER) allows UK counterparties to apply for intragroup exemptions
  Source update
• CP25/2: Proposed changes to MiFID conduct of business rules for retail investors
  The FCA is consulting on amendments to COBS to strengthen protections for retail investors accessing complex investment products. The proposals include enhanced disclosure requirements for ESG-labeled funds and stricter appropriateness assessments. The consultation closes on 15 April 2025. Investmen
  Source update
• CP26/5: Aligning listed issuers’ sustainability disclosures with international standards
  Discover our proposals to evolve our rules for listed companies' sustainability disclosures. ... Read CP26/5 (PDF)Why we are consultingSustainability risks, including climate risks, have financial impacts on the long-term value and resilience of listed companies.We’re consulting on replacing our cur
  Source update

Practical Actions for Firms

1. Review whether current policies need updates in response to these notices.
2. Assess whether any deadlines or implementation dates apply to your business model.
3. Document the impact assessment and assign internal owners for follow-up actions.

How MEMA Can Help

MEMA can support with impact assessments, implementation planning, and policy/document updates aligned to FCA expectations.

Why This Matters

Senior management and compliance teams need clear ownership, practical controls, and evidence-ready execution to stay on track.

Implementation Checklist

1. Define accountable owners, scope, and implementation deadlines.
2. Map required policy/control changes and assign testing requirements.
3. Capture evidence standards, board reporting expectations, and escalation triggers.

Action Timeline (30/60/90 Days)

Use a practical 30/60/90-day delivery cadence to move from assessment into evidenced implementation.

Timeline	Primary objective	Evidence output
Days 1-30	Triage top FCA updates and assign accountable owners.	Impact log, owners, and prioritised actions
Days 31-60	Update impacted policies, controls, and client communication plans.	Updated procedures and test results
Days 61-90	Present board-ready evidence pack and residual risk sign-off.	Governance report and assurance record

If you want a tailored implementation plan, book a consultation with MEMA: Book Consultation. For supporting resources, visit the Resource Library.