Deferred Payment Credit (DPC) Regulation FAQs: What you need to know

Who are the FCA?

The Financial Conduct Authority (FCA) is the main regulator for financial services in the UK.

Their role is to:

• Protect consumers
• Maintain the stability of the financial system
• Promote healthy competition

Zopa is authorised and regulated by the FCA and follows all relevant rules and principles.

What is DPC regulation and where has it come from?

Deferred Payment Credit (DPC) is the FCA’s formal name for what has historically been called Buy Now Pay Later (BNPL) or unregulated retail finance.

It refers to interest-free credit that is:

• Repaid in 12 or fewer instalments
• Completed within 12 months or less
• Provided by a third-party lender at checkout

Where has it come from?

• In July 2025, the Government passed legislation bringing DPC into regulation
• The rules come into force on 15 July 2026
• The FCA published final rules in Policy Statement PS26/1 (February 2026)

Who does this regulation apply to?

The regulation applies to lenders like us, not to you as a merchant.

Applies to:

• Third-party lenders providing the credit
• Firms entering into credit agreements with customers

Does NOT apply to:

• Merchants offering finance at checkout

The activity you perform (presenting finance as a payment option) is explicitly exempt from regulation.

Bottom line

The regulation sits with us as the lender.
Your role remains unchanged and unregulated.

Why does the regulation start on 15 July 2026?

The Government set 15 July 2026 as the date when all new DPC agreements must be regulated.

• Agreements before this date remain unregulated
• Agreements after this date fall under FCA rules

The FCA used the period between 2025–2026 to finalise the rules.

Why has the name changed from BNPL to DPC?

“Deferred Payment Credit” is the legal term used in Government legislation.

The FCA avoids “BNPL” because:

• It already applies to some regulated products
• It can refer to different types of credit

In practice

• DPC = BNPL / Unregulated Credit (same customer experience)

Important 

You must stop using the term “unregulated credit”, as it will no longer be accurate.

Do I need FCA authorisation to offer finance after 15 July 2026?

No. You do not need FCA authorisation in any capacity.

You do not need to:

• Register with the FCA
• Become a credit broker
• Apply for permissions

If I don’t need authorisation, why am I receiving these updates?

While the regulation sits with us, there are a small number of practical actions for you.

What you need to do

• Remove references to “unregulated” credit and any wording suggesting the product sits outside FCA regulation or Financial Ombudsman Service protections

You do not need to sign a new merchant agreement. You'll have 10 business days to consider any updated terms we need to make. You don't have to do anything if you're happy with the changes, they'll automatically take effect at the end of the 10 business days.

We’re sharing this early so you have everything you need well ahead of the deadline.

What do I need to change in my marketing materials?

You need to remove any wording that describes the product as "unregulated credit" or suggests it sits outside FCA regulation or Financial Ombudsman Service protections.

After 15 July 2026:

• The product is regulated
• Using “unregulated” or any wording suggesting the product is outside FCA regulation or Financial Ombudsman Service protections, will be factually incorrect and non-compliant

Where this applies

• Website content
• Checkout messaging
• Marketing materials

We’ll provide:

• Design assets and updated customer messaging
• Guidance on the marketing materials and approved terminology that can be used when promoting the product

What language should I use instead?

We’ll provide updated customer messaging, approved terminology, and guidance to help you update customer-facing content compliantly.

Can I still describe the product as ‘interest-free’?

Yes — and you should.

“Interest-free”:

• Is accurate
• Is consumer-friendly
• Is required to be shown under FCA rules

What are affordability checks?

From 15 July 2026, we must assess whether a customer can afford the credit.

This is based on FCA creditworthiness rules (CONC 5.2A).

What changes

• Affordability is formally assessed and documented
• A consistent, auditable process is required

Important

We already perform credit checks today — this formalises the process.

Will acceptance rates change?

We do not expect a material impact on approval rates.

We will:

• Monitor performance
• Share monthly insights from August 2026

Will the application process take longer?

No.
Affordability checks are instant, so there is no added delay.

What new information will customers see at checkout?

Customers will receive additional regulated pre-contract credit information, including key credit terms and customer protections. Including:

• Total amount of credit 
• Rate of interest
• Repayment schedule 
• Consequences of missed payments
• Explanation of 14 day right of withdrawal
• Section 75 explanation 

Who is responsible for displaying this information?

We are.

We:

• Build and manage all disclosures
• Update the checkout experience

You do not need to:

• Write content
• Build components
• Host any disclosures

Do I need to update my website or checkout?

For most merchants: No.

Exception

If you use a custom integration, you may need minor updates.

If this applies, we will:

• Contact you directly
• Provide technical guidance

What is the Financial Ombudsman Service (FOS)?

The Financial Ombudsman Service is an independent body that resolves disputes between consumers and financial providers.

From 15 July 2026, DPC falls under its jurisdiction.

What happens if a customer goes to the FOS?

• The customer submits a complaint
• The FOS contacts us (the lender)
• We provide the case and respond
• The FOS issues a decision

Important

• You are not involved in the process
• You do not deal with the FOS directly

If a customer raises this:
👉 Pass it to us and we will handle it

What is the 14-day withdrawal right?

Customers can withdraw from the credit agreement within 14 days.

What this means

• The credit agreement is cancelled
• Customers will no longer owe repayments under the credit agreement, although they may still remain liable for payment for any goods or services already received, in line with the applicable terms and conditions

How does this interact with my returns policy?

The withdrawal right and your returns policy are separate.

If the item is returnable

• Customer withdraws from credit
• Customer returns the item
• Outcome = standard return

If the item is non-returnable

• Credit is cancelled
• Customer still owes you for the product

Why is my merchant agreement being updated?

The legal framework for lending changes under regulation.

Your agreement needs to reflect:

• FCA jurisdiction
• Consumer Credit Act protections, including Section 75 and other applicable protections, such as Sections 56 and 140A where applicable
• 14-day withdrawal rights

What’s not changing

• Commercial terms
• Pricing
• Settlement
• Commission

What does regulation say about late fees?

Late fees must be cost-reflective under FCA rules.

What is Zopa’s late fee policy?

We charge zero late fees.

• We have never charged them
• We will not introduce them under regulation

A missed payment will not result in a financial penalty from us.