• Robert Kraal, Co-Founder at Silverflow


• 16.07.2026 09:15 am
#BuyNowPayLater

Most of the debate about the FCA's new Buy Now, Pay Later rules has focused, understandably, on the consumer. Less has been said about the infrastructure that has to process each payment, and that is where the real work begins.

From 15 July, whether a Deferred Payment Credit agreement is regulated depends on the relationship between lender and merchant, and on when the agreement was signed. Regulated and unregulated payments are still going to be moving on the same payments rails. Acquirers and processors now have to distinguish regulated from unregulated DPC at the level of the individual transaction, account for new Section 75 refund exposure, and support the dispute, reporting and consumer duty obligations that follow. If an acquirer or processor doesn’t have that information then they can’t be compliant.

Much of the processing infrastructure underpinning these products was never designed for that kind of granularity. Legacy platforms built decades ago struggle to tag, trace and report at the resolution modern regulation now assumes, which is precisely why so much compliance cost ends up buried in manual work and reconciliation.

Good regulation deserves infrastructure that can actually deliver it. The firms that treat data richness and real-time reporting as core capabilities rather than after-thoughts will absorb these changes with far less friction, while companies still working with decades old legacy technology will struggle to keep up.