The FCA has published a consultation paper (CP25/23) on how it proposes to regulate what will become known as deferred payment credit (DPC). DPC is one form of what is currently unregulated buy-now-pay-later (BNPL) credit, and is where a third-party lender funds the credit in a borrower-lender-supplier relationship. This follows the response issued by HM Treasury in May 2025 to its earlier consultation on the regulation of BNPL credit in late 2024. The response established that the government did not intend to regulate BNPL credit where the credit is provided by the supplier of the goods or services (the merchant).