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. The focus is on operational execution, accountability ownership, and evidence-ready implementation rather than policy interpretation alone.

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 CP26/7: Credit Information Market Study: Proposed approach to imple... 88 CP25/2: Proposed changes to MiFID conduct of business rules for ret... 85

Higher bars indicate higher relative operational or compliance impact.

What Changed / What This Means Now

The current FCA publication cycle raises the practical bar for firms to evidence timely remediation and governance oversight. Firms that delay implementation planning will find it harder to demonstrate control effectiveness during supervisory engagement.

Who Is Exposed

Firms with active customer-facing products, evolving disclosures, and board-level conduct/accountability obligations should treat these updates as immediate execution priorities.

Operational Impact by Function

Function	Impact	Required output
Compliance	Policy delta and control design uplift	Signed impact assessment and owner mapping
Legal	Disclosure and communication wording updates	Approved wording library and escalation guidance
Operations	Process and QA workflow changes	Updated SOPs, QA evidence, and remediation log
Leadership	Board oversight and risk acceptance decisions	Decision log and monthly execution checkpoint

30/60/90-Day Action Kit

Timeline	Primary objective	Evidence output
Days 1-30	Prioritise impacted policy, client, and control journeys.	Impact register and owner map
Days 31-60	Deploy control updates and test exception pathways.	QA results, remediation backlog, and MI
Days 61-90	Run governance sign-off and residual risk review.	Board pack and assurance evidence

Risk & Control Matrix

Risk area	Failure mode	Control response
Governance ownership	No clear owner for remediation actions.	Named accountable owner with escalation cadence.
Control testing	Policy updates are not tested in BAU workflows.	Risk-based QA testing and exception trend analysis.
Client comms	Messaging outpaces approved legal wording.	Central approved wording, change control, and QA review.

Board Briefing Pack

Update	Impact rating	Board question
PS26/1: Regulation of Deferred Payment Credit (unregulated Buy Now Pay Later)	High	Define accountable owner, client messaging delta, and evidence checkpoint by next governance cycle.
CP26/1: The Value for Money Framework: Response to consultation, further consultation and discussion paper	High	Define accountable owner, client messaging delta, and evidence checkpoint by next governance cycle.
CP25/30: Streamlining the UK EMIR Intragroup Regime	High	Define accountable owner, client messaging delta, and evidence checkpoint by next governance cycle.
CP26/7: Credit Information Market Study: Proposed approach to implementing FCA remedies	High	Define accountable owner, client messaging delta, and evidence checkpoint by next governance cycle.
CP25/2: Proposed changes to MiFID conduct of business rules for retail investors	High	Define accountable owner, client messaging delta, and evidence checkpoint by next governance cycle.

Client Communication Guidance

Explain clearly what changed, what clients should expect, and when updates will be completed. Avoid broad assurances that cannot yet be evidenced by tested controls.

MEMA POV

MEMA POV: the strongest firms treat regulatory updates as operating model events. They combine policy interpretation with delivery ownership, quality assurance checkpoints, and board-ready evidence from the start.

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
• CP26/7: Credit Information Market Study: Proposed approach to implementing FCA remedies
  We are consulting on proposals designed to improve how consumer credit information is shared and used across retail lending markets. ... Read CP26/7 (PDF)Why we are consultingOur proposals include a mandatory reporting requirement for firms in the credit and mortgage markets and connected obligation
  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

Implementation Checklist

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.

Risk & Control Matrix

Control design should balance operational feasibility with audit-ready evidence quality.

Risk area	Failure mode	Required control response
Governance ownership	Actions have no accountable owner and drift between teams.	Named accountable owner, deputy, and documented escalation route.
Control testing	Controls are updated but not evidenced through QA testing.	Risk-based sample testing with remediation and exception trend MI.
Evidence quality	Assurance packs cannot demonstrate traceability to FCA update implementation.	Traceable evidence pack aligned to policy, control, and governance outcomes.

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