Select Regulatory Regimes

Which jurisdictions apply to your BNPL product?

Select all that apply. The tool will load the relevant obligation checklist for each selected regime.

🇬🇧 FCA · Deferred Payment Credit

UK Consumer Credit Act 1974 (as amended by FSMA 2023). FCA authorisation, CONC rules, affordability, right of withdrawal, financial promotions.

FSMA 2023 CONC CCA 1974 7 obligations

🇪🇺 EU · Consumer Credit Directive 2

Directive 2023/2225. Repeals CCD1 (2008/48/EC). Explicitly includes BNPL in scope. SECCI disclosure, APR, creditworthiness assessment, right of withdrawal.

CCD2 2023/2225 SECCI EU-27 7 obligations

🇺🇸 US · CFPB Regulation Z

Truth in Lending Act (TILA) implementation. 12 CFR 1026. CFPB BNPL interpretive rule (2024) classifies most BNPL as closed-end credit subject to Reg Z.

12 CFR 1026 TILA CFPB 2024 5 obligations

🗽 NY DFS · BNPL Supervisory Guidance

NY DFS Guidance (June 2023). Consumer disclosure, credit reporting, data privacy and sharing restrictions, customer complaint mechanism requirements.

NY DFS Jun 2023 23 NYCRR 4 obligations

Please select at least one regulatory regime to continue.

Assess Each Obligation

Rate your current compliance status per obligation

For each obligation, select the status that best reflects your product's current posture. Use N/A only if the obligation is genuinely inapplicable (e.g. a jurisdiction-specific exemption applies).

All unrated obligations default to Fail for conservative scoring.

Assessment incomplete — please review obligations above.

Source Notes & Regulatory Citations

Financial Services and Markets Act 2023, Schedule 9 — removes BNPL exemption from CCA 1974 s.60F(2); FCA policy statement expected mid-2025. Effective date: 15 July 2026.
FCA CONC 4.2 — Pre-contract disclosure requirements; CONC 5.2A — Creditworthiness assessment; CONC 6 — Post-contract obligations. FCA Consumer Credit sourcebook, version in force from July 2026.
Consumer Credit Act 1974, s.66A — right of withdrawal for regulated credit agreements; 14-calendar-day cooling-off period from agreement date.
Directive 2023/2225/EU (CCD2) — repeals Directive 2008/48/EC. Published OJ L 2023/2225. Transposition deadline: 20 November 2025. Member states may apply CCD2 to agreements below EUR 200.
CCD2 Art. 18 — creditworthiness assessment; Art. 26 — right of withdrawal (14 days); Art. 29 — right of early repayment; Art. 31 — APR calculation using actuarial method; Annex II — SECCI format.
12 CFR Part 1026 (Regulation Z) — Truth in Lending Act implementation. CFPB interpretive rule on BNPL (May 2024): 4-installment BNPL treated as closed-end credit per § 1026.2(a)(17)(iv).
CFPB Advisory Opinion on BNPL (March 2023); CFPB Supervisory Highlights Spring 2023 — BNPL practices; 12 CFR 1026.13 — billing error resolution; 12 CFR 1026.7 — periodic statements.
NY DFS BNPL Supervisory Guidance, June 2023 — sets expectations for disclosure, credit reporting (§3), data privacy (§4), and consumer complaints (§5) for BNPL providers operating in New York State.
Methodology: obligations scored Pass=1.0, Partial=0.5, Fail=0.0. N/A obligations excluded from denominator. Composite score = weighted average across all selected jurisdictions. Tier: ≥80 Compliant, 60–79 Near-Compliant, 40–59 Partial, <40 Non-Compliant.

FCA BNPL / DPC Readiness Checker