Karsten Wenzlaff, Advisor
August 26th, 2025
Karsten Wenzlaff is a Crowdfunding and Fintech Expert from Germany. He is Secretary-General of Digit[...]
UK Exempts In-home BNPL Sellers From Licensing
BNPL | June 17, 2025
UK Removes BNPL Broker Licensing Rule for In-home Sellers
On June 16, 2025, the UK HM Treasury published a policy update that says 'domestic premises suppliers' (aka door to door vendors or companies that provide goods or services in a customer's home) no longer need to be licensed as credit brokers to offer Buy Now Pay Later (BNPL) services. The change to BNPL regulation is aimed at supporting smaller businesses without weakening consumer protections. This exemption includes services like home improvement consultations, kitchen installations, in-home services like cleaning or fitness, or any other sale that takes place during a visit to the customer's home.
Why the Exemption Was Made
Many industry stakeholders warned that requiring a credit broker license for these types of businesses isn't necessary and overly burdensome. The government agreed because these in-home suppliers do not offer financial services as their primary business activity. Instead, the typically introduce customers to a single BNPL lender as part of a product or service sale. Additionally, regulators realized that the risk of consumer harm in these cases is relatively low since the financial exposure sits with the BNPL lender who is regulated, not the seller, and felt that requiring small businesses to apply and maintain broker requirements is disproportionate to their role.
See: GPR 2025 Shows Rise of Wallets BNPL and Real-Time Payments
While the sellers are now exempt, BNPL lenders will still be fully regulated under the new rules, and must perform creditworthiness and affordability checks and comply with FCA Consumer Duty requirements. They must also ensure that purchases made using BNPL are protected under Section 75 of the Consumer Credit Act 1974, and that customers have access to the UK’s Financial Ombudsman Service to address complaints.
The full BNPL regulatory framework in the UK is expected to come into force by mid-2026, including secondary legislation to implement the exemption for in-home sellers.
What's Happening in Canada
Canada doesn't currently have a dedicated national BNPL regulatory framework. It also doesn't require BNPL sellers to have a credit-brokering license. The Financial Consumer Agency of Canada (FCAC) continues to monitor the sector but doesn't directly regulate BNPL lending. Oversight is through a mix of provincial consumer protection laws and federal rules related to money laundering and data privacy.
See: Open Banking Delayed But Back in the Legislative Radar
In Ontario as an example, BNPL offerings must comply with the Consumer Protection Act, which requires clear disclosures and restricts misleading marketing. If a provider handles payments, they may also need to register as a money services business under federal law.
Outlook
As BNPL continues to grow, pressure is building for regulators to provide clearer guidance. The UK’s model may offer a useful reference for policymakers looking to balance access to BNPL services while protecting Canada's evolving credit sector.
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