On 14 July 2025, there was made The Financial Services and Markets Act 2000 (Regulated Activities etc.) (Amendment) Order 2025. The statutory instrument will bring interest-free Buy-Now, Pay-Later (BNPL) agreements into regulation under the Financial Services and Markets Act 2000 (Regulated Activities) Order 2001 (RAO). The statutory instrument also introduces a new exemption from Article 36A of the RAO (regulated activity of credit broking), ensuring that most merchants (e.g. e-commerce websites) are not subject to credit broking regulations when they refer customers to third-party BNPL providers (e.g. offering a third-party BNPL product at checkout, not their own finance product).

