Buy Now Pay Later Complaints

Buy Now Pay Later in the UK has gone through a complex regulatory evolution:

Pre-regulation BNPL: Products that deferred payment without interest and repayable within 12 months were historically exempt from the Consumer Credit Act 1974 under Section 12 of the Financial Services and Markets Act 2000. This meant providers did not need FCA authorisation and customers had fewer statutory protections.

FCA oversight requirements: Following pressure from consumer groups and the Woolard Review (2021), the FCA required some BNPL providers to voluntarily comply with certain FCA rules while formal regulation was introduced.

Moving to full regulation: The government confirmed in 2024 that BNPL products will be brought fully under the Consumer Credit Act framework. This means:

• Providers will need FCA authorisation
• Mandatory affordability assessments before credit is provided
• Regulated complaint handling and access to the Financial Ombudsman Service
• Section 75 protections for qualifying purchases
• Clear pre-contract information requirements

Until full regulation takes effect, your rights depend on whether the specific BNPL product you used was already regulated. Check whether your provider is FCA-authorised on the FCA Register at register.fca.org.uk.

If goods or services purchased using BNPL go wrong — they are faulty, not delivered, or materially different from what was advertised — you should:

1. Contact the retailer first — attempt to resolve the dispute directly with the seller. Under the Consumer Rights Act 2015, you have statutory rights to a repair, replacement, or refund for faulty goods.
2. Withhold payment to the BNPL provider — if you have a genuine dispute with the retailer, some BNPL providers allow you to pause your repayments while the dispute is investigated. Check the provider's terms.
3. Raise a dispute with the BNPL provider — contact the BNPL company directly and explain the dispute. If the provider is FCA-regulated, they have duties to treat you fairly and engage with your dispute.
4. Escalate to the FOS — if the BNPL provider is FCA-regulated and does not resolve your complaint within eight weeks, you can escalate to the Financial Ombudsman Service for free.

For unregulated BNPL products, your options are more limited. You may need to pursue the retailer directly through trading standards, small claims court, or — if you paid partly by credit card — a Section 75 claim against the card issuer.

A growing number of BNPL providers now report account information — including missed payments and defaults — to one or more of the three main UK credit reference agencies (Experian, Equifax, and TransUnion). This is a significant change from earlier BNPL products, which often had no impact on credit files.

Key points:

• If you miss BNPL payments, these may appear as missed payments or defaults on your credit file for six years
• This can affect your ability to get a mortgage, credit card, or loan
• You may receive no prior warning before a missed payment is reported — check your BNPL provider's credit reporting policy
• Equally, timely BNPL payments may now help build your credit history with some providers

If you notice an incorrect entry on your credit file relating to a BNPL account, you can raise a dispute with the credit reference agency and with the BNPL provider. See our guide on Credit Reference Disputes for the full process.

If you used a regulated BNPL product and believe the provider failed to carry out adequate affordability checks before lending to you — for example, if you were clearly in financial difficulty, had other significant debts, or the repayments were obviously unaffordable — you may have grounds for an affordability complaint.

Affordability complaints in the BNPL context are relatively new, but follow similar principles to those used successfully against payday lenders and credit card companies. To succeed, you would need to show that:

• The provider extended credit without properly assessing whether you could afford to repay
• A proper assessment would have revealed the lending was unaffordable
• You suffered financial harm as a result (such as falling into arrears or needing to borrow more to pay)

If your affordability complaint is upheld, the provider may be required to write off some or all of the interest and charges (though many BNPL products charge no interest), remove negative marks from your credit file, and/or refund payments made that should not have been taken.