BNPL (Buy-Now-Pay-Later)

Merchant refund not reflected - installments still demanded; No affordability check - consumer over-indebted; Late fee / charge not disclosed at checkout

Mandatory ADR

Max award: £445,000 (from 1 Apr 2025)

8 weeks firm; FOS 6 months (if in jurisdiction)

Uphold rate: 34% (FOS 2024/25)

Key Legislation

Consumer Rights Act 2015 (pre-regulation); CCA 1974 (post-July 2026); FCA CONC 5.2 (from July 2026); CCA 1974 (from July 2026) — CRA 2015 s.49-52; CCA 1974 s.75 (from July 2026); FCA CONC (from July 2026); CONC 5.2A; Consumer Duty PRIN 2A; CCA 1974 s.140A (from July 2026)

Complaint Route: Financial Ombudsman Service

Type: Ombudsman (binding on firm)

Max award: £445,000

Uphold rate: 34%

Average resolution: 180 days

Pre-conditions: Complain to firm first; firm has 8 weeks to resolve; then refer to FOS within 6 months of final response

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Companies in This Sector

Klarna (FCA 536065)Clearpay (FCA 902086)PayPal Pay in 3 (FCA 604278)Zilch (FCA 928005)

Annual complaint volume: 305,726 (FOS 2024/25 total)

Note: Compensation range: Refund of charges; credit marker removed

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Coverage

Tier 1 — Financial (FOS expertise)