Since it emerged onto the retail scene more than a decade ago, BNPL, or Deferred Payment Credit (DPC), came under the regulatory umbrella for the first time in July 2026 when it became subject to the Consumer Duty. Since then, DPC has become a mainstream part of the eCommerce landscape, converting demand and boosting confidence.
The regulations are part of deliberate, proportionate steps to make DPC work better for consumers. Measures include affordability checks, clearer protections and greater accountability to build transparency, fairness and trust in a market that has grown quickly without any significant regulatory oversight.
Although a welcome step forward, there are concerns that compliance is opening new risks: how to protect consumers while maintaining fair access.
One estimate is that 10-30 per cent of BNPL users could face rejection as a result of the affordability checks now required. The worry for retailers is that this could include many customers who can afford the monthly repayments.
For retailers, this is a tangible risk. Customers can reach checkout ready to buy, only to be declined or pushed into a manual referral that breaks the shopping journey. The result is abandoned baskets, lost sales and a drop in consumer confidence.
It may also nudge consumers down less suitable or riskier, unregulated options, exposing them to potential financial harm. This highlights how the issue is not just commercial, but also ethical, and at a time of rising acquisition costs and tight margins, retailers cannot treat approval rates as a problem for lenders alone.
The question for eCommerce is simple: how can retailers preserve access responsibly and fairly?
The affordability challenge
It's worth highlighting that this is not a new issue resulting from the latest regulations. Throughout the UK, around 20.2 million adults are financially underserved, meaning they struggle to access the market-dominating 0% and lower-APR point-of-sale finance.
A key factor behind this is decisioning tools not keeping pace with the financial lives of those who don't fit conventional credit models. This includes features such as thin files, limited histories or fluctuating, non-linear incomes.
It is the reliance on bureau data which risks exacerbating the credit access challenge for DPC users as retailers and lenders comply with the new regulatory landscape. Customers who are most at risk include self-employed workers with stable earnings, new credit users and recent UK arrivals who are building credit files.
Under the new DPC rules, relying on bureau data alone is no longer enough. Although bureau data is still important, it cannot always verify income or reflect the way people earn and manage money today.
Income verification as part of affordability checks can be highly challenging and requires a combination of experience, knowledge and technical capabilities. The focus is on building a rich profile of a customer in a low-friction journey to maintain momentum in the buying journey.
This understandably represents a daunting technical challenge for eCommerce and their DPC partners, and tackling it requires an urgent look at the role of inclusive lending.
Given the challenge of maintaining fair access for DPC users, it is increasingly clear that inclusive lending will become a growing priority for the sector's compliance models now and in the future.
Harnessing inclusive lending
Painting a richer affordability profile has been a focus for specialised operators in the inclusive lending sector like Snap Finance UK (Snap) for years.
Throughout this time, the core focus has been supporting the millions of near-prime consumers struggling to access credit and helping retailers say "yes" more often and convert demand that would otherwise be lost through credit declines.
Harnessing inclusive lending does not mean fewer, or less rigorous, checks. It is a more holistic affordability view, built from richer, intelligently connected data.
This includes traditional and additional data sources consolidated in a digital-first lending ecosystem to ensure a seamless process for consumers and retailers.
For example, at Snap, we combine Open Banking, HMRC and transaction-level data to generate accurate, real-time, genuine affordability assessments without adding friction to the checkout.
This tried and tested approach has already unlocked significant demand. In the first half of 2026, 22,527 initially declined customers were referred to our enhanced Open Banking journey, and 5,450 were subsequently approved.
More approvals don't mean increased risk. It means using better evidence and advanced decision science to assess genuine affordability, widen access where appropriate and keep eligible customers in the buying journey.
Beyond increasing approvals – where could retail finance go?
One of the conversations the new regulatory landscape should trigger is the value of multi-lender retail credit strategies.
This doesn't mean lender competition, but complementary capabilities delivering real value.
We already see this at Snap when declined customers are referred to us to provide a second chance rather than an abrupt end to the sale.
Yet there are also opportunities when inclusive lending is offered upfront.
Our surveys show that 39% of customers are confident they know which lenders will approve them, so presenting choice and flexible options at checkout which may better suit their circumstances is key to reducing uncertainty.
For example, with SnapFlex, 33% of consumers choose interest-bearing finance over a 0% offer because the lower monthly repayments are more manageable for them.
Retailers are also seeing success. Sleep technology brand Simba Sleep increased its average order value by 50% compared with the site norm after partnering with Snap to broaden credit choice and boost consumer confidence, empowering them to fill their baskets with complementary products for better quality sleep.
The future of retail credit will be based on balancing protection with responsible, fair access.
Compliance must not dilute inclusion or leave customers who can afford to repay without an appropriate route to credit.
For eCommerce retailers, inclusive lending is therefore no longer a niche alternative. It is an unmissable, and practical way to protect conversion, sustain growth and give more eligible customers a fair route to finance.