However, members recognise the limitations of the Consumer Credit Act 1974 (CCA) for today’s digital environment and as such support a pragmatic regulatory approach, which sees the disapplication of outdated CCA requirements to Buy-now, Pay-later (BNPL) regulated lending and consideration of a more proportionate regulatory regime focused on achieving good customer outcomes.  

Such a position is adopted in the expectation that timely broader CCA reform is introduced, which similarly disapplies outdated CCA requirements and enables firms to better support customers to achieve good outcomes for other regulated products.

As such, our members support the approach positioned by HM Treasury, though would urge it and the Financial Conduct Authority (FCA) to continue to monitor the sector to address any emerging harm.