On 3 November 2025, The Financial Services and Markets Act 2000 (Regulated Activities etc.) (Amendment) (No. 2) Order 2025 was made together with an explanatory memorandum.

The Order comes into force on 3 December 2025.

The Order will exempt domestic premises suppliers from credit broking regulation under the Financial Services and Markets Act 2000 (Regulated Activities) Order 2001 (RAO) when they offer newly regulated interest-free Buy-Now, Pay-Later (BNPL) products to their customers. It does this by amending the Financial Services and Markets Act 2000 (Regulated Activities etc) (Amendment) Order 2025 (the 2025 Order) and Article 36FB of the RAO inserted by the 2025 Order.

The Order also makes certain technical amendments relating to the transitional provisions in Part 4 of the 2025 Order which are intended to clarify the status of authorised firms with existing Part 4A permission to carry on an activity specified by Article 60B (regulated credit agreements), prior to the regulatory commencement date. The effect of the amendments is that when BNPL products become regulated on 15 July 2026, firms with existing Part 4A permission to carry on an activity specified by Article 60B (regulated credit agreements) will be treated as having permission to lend newly regulated BNPL products on or after that date. This is in line with the policy intent.