Buy now, pay later problems: your rights under the new 2026 rules

From 15 July 2026, buy now, pay later (BNPL) becomes regulated credit in the UK. Lenders like Klarna and Clearpay must check you can afford to repay, explain the agreement clearly, support you if you struggle - and, for agreements from that date, you get access to the Financial Ombudsman Service for free if things go wrong.

That is a genuine shift in your favour. But the detail matters, especially the cut-off: agreements taken out before 15 July 2026 stay unregulated. Here is what changes, what does not, and how to handle the most common BNPL problems either side of the line.

Key takeaways

• From 15 July 2026 the FCA regulates "deferred payment credit" - interest-free BNPL repayable in 12 or fewer instalments within 12 months.
• New agreements come with affordability checks, clear pre-contract information, and Financial Ombudsman access.
• Section 75 protection can apply to regulated BNPL purchases with a cash price over £100 and up to £30,000.
• Agreements from before 15 July 2026 remain unregulated - complain to the firm, and use retailer and card routes where they fit.
• BNPL provided directly by the seller of the goods stays outside the regime.
• Escalating a regulated complaint to the Financial Ombudsman Service is free.

What exactly is being regulated?

The new regime covers third-party BNPL - the checkout options provided by a lender that is not the retailer - where the credit is interest-free and repaid in 12 or fewer instalments within 12 months. Firms need FCA authorisation (or temporary permission while their application is processed).

What the rules require of lenders, for agreements from 15 July 2026:

• Affordability: proportionate checks that you can afford the repayments before lending
• Clarity: key information up front - amounts, due dates, what happens if you miss a payment, late fees
• Support: if you get into difficulty, the firm must engage and, where appropriate, point you to free debt advice
• Accountability: complaints the firm rejects can go to the Financial Ombudsman Service

Sources: FCA consumer guidance on buy now pay later and the FCA's announcement of the new BNPL protections. Last checked: 04.07.2026.

Which rules apply to your agreement?

Question	Before 15 July 2026	From 15 July 2026
Is the lender FCA-regulated for BNPL?	No	Yes (or temporary permission)
Affordability checks required?	No	Yes
Financial Ombudsman access?	No (for the BNPL lending itself)	Yes
Section 75 protection?	No	Yes, for eligible purchases (£100-£30,000 cash price)
Can you still complain to the firm?	Yes - always	Yes

The date that matters is when the agreement was entered into, not when the problem arose.

The most common BNPL problems - and the route for each

The retailer took a return, but the BNPL plan keeps charging

This is the classic one. The refund sits with the retailer or is "processing" while instalments keep collecting, sometimes with late fees on top. Gather the return proof and refund confirmation, then complain to the BNPL firm in writing: the schedule should have been adjusted, and fees charged on a refunded balance should be reversed. For a regulated agreement, a rejection can go to the Ombudsman.

Goods never arrived, or arrived faulty

Your consumer rights against the retailer exist regardless of how you paid. From 15 July 2026, regulated BNPL adds a second target: under Section 75, the lender can be jointly responsible for the retailer's breach of contract or misrepresentation on eligible purchases over £100. For older agreements, pressure the retailer directly - and if any BNPL instalments were collected from a credit or debit card, a chargeback on those payments may be worth exploring.

Late fees you think are unfair

Check what you were shown at checkout: the amount and timing of instalments and the fee terms. If the firm's app or emails were unclear, or a payment failed because of the firm's own processing, say so specifically. From 15 July 2026, clarity is a regulatory requirement, not a courtesy.

You could never really afford the plans

BNPL's structural risk is stacking: several plans across several firms, each small, together unmanageable. For agreements from 15 July 2026, lenders must assess affordability - and a pattern of lending into visible difficulty looks a lot like the established unaffordable lending complaint. For older agreements there is no such requirement to point to, but firms still handle hardship complaints, and support obligations apply once you tell them you are struggling.

Credit-file surprises

BNPL firms increasingly report to credit reference agencies. If a disputed balance - say, on returned goods - produced a missed-payment marker, include the credit-file correction in what you ask for.

How to complain to a BNPL firm

1. Identify the agreement: purchase, date, retailer, plan reference.
2. State the problem in one sentence: refund not applied, goods not received, fee charged in error, unaffordable lending.
3. Timeline the key events, with dates: order, return, refund promise, instalments taken, fees added.
4. Attach the evidence: order confirmation, return tracking, refund emails, statements, screenshots of the app.
5. State the outcome you want: instalments stopped or refunded, fees reversed, credit file corrected.

Firms generally have up to eight weeks to give a final response.

When and how to escalate

For agreements taken out from 15 July 2026, if the firm rejects your complaint or eight weeks pass, you can take it to the Financial Ombudsman Service. The Financial Ombudsman Service is free, independent, and you keep any compensation it awards. The usual six-month window from the final response applies - check the current time limits.

For context, our analysis of published Ombudsman decisions shows loans and credit complaints often perform differently from banking disputes, but the 15 July 2026 cut-off still controls the route.

For older agreements, the Ombudsman generally cannot look at the BNPL lending itself - use the retailer, chargeback and firm-complaint routes above, and be persistent.

How HeyRefund can help

BNPL disputes look small but tangle quickly: a retailer, a lender, an app, a credit file - and now two regulatory regimes depending on a date. HeyRefund helps you organise the purchase trail, the payment record and the complaint into something clear enough that the firm cannot lose it in the queue.

Complaining is free at every stage, and you keep anything awarded. HeyRefund just does the organising.