POLICY RESEARCH PAPER · MAY 2026
Buy Now, Pay Later: From
Regulatory Blind Spot to
Global Policy Priority
A regulatory intelligence report for financial sector authorities and policymakers in emerging and developing markets.
The global regulatory direction is unmistakable. Between 2024 and 2026, more jurisdictions enacted BNPL-specific regulation than in the previous decade combined. If your market has not yet moved, this report is for you.
DOES THIS SOUND FAMILIAR?
Are you a financial regulator watching BNPL providers operate in your market with no clear legal basis to reach them?
Wondering whether your jurisdiction’s consumer credit law actually covers BNPL, or whether providers have already structured their way around it?
Concerned that consumers in your market are taking on credit obligations that neither you, nor other lenders, nor the borrowers themselves can fully see?
BNPL is a financial credit product, not a payment method. This distinction is not trivial. It determines who regulates it, what disclosures apply, and what protections consumers can expect.
WHAT YOU WILL FIND IN THIS REPORT
Where BNPL is growing fastest and why that should concern you
BNPL reached an estimated $560 billion in global transaction volume in 2025. Africa’s market is projected to grow from $5.2 billion to $16.8 billion by 2031. Asia-Pacific is already a $211 billion market. The growth frontier is precisely where regulatory frameworks are thinnest and where consumers have the least protection when things go wrong.
The harm that is already happening at scale
Between 34 and 41% of BNPL users globally miss at least one payment. In the UK, 22% of users missed repayments within a six-month period, with 1 in 4 of those subsequently facing credit score damage or contact from debt collectors. These are not projections or modeled risks. They are documented outcomes occurring now, in markets where reporting infrastructure remains absent or underdeveloped.
The phantom debt problem and why it will not self-correct
Because BNPL obligations are largely absent from credit registries, borrowers can accumulate liabilities that are invisible to lenders, regulators, and sometimes themselves. Standard credit metrics, including credit scores and debt-service ratios, are failing to capture this exposure. Without mandatory reporting, neither the market nor voluntary industry measures can resolve this. It requires regulatory intervention.
The regulatory response: four models from eight jurisdictions
Australia, the UK, the EU, Malaysia, Oman, Kenya, Nigeria, and Ghana have each enacted or advanced BNPL-specific regulation. This report maps four regulatory design models: credit-law integration, harmonized supranational directive, bespoke dedicated instrument, and digital lending framework extension. It analyzes what each achieves, what it costs institutionally, and what it leaves unresolved. For emerging markets considering their approach, this comparative analysis is the starting point.
A practical Five-Pillar Framework designed for emerging markets
Built on a decade of work with financial sector authorities across Africa, Asia, and Latin America, this report proposes a framework that regulators can actually implement, sequenced by institutional capacity, not by ideal conditions.
Pillar 1: Market Transparency, know who is operating and at what scale
Pillar 2: Minimum Disclosure Standards, ensure consumers understand what they are agreeing to
Pillar 3: Creditworthiness Assessment, proportionate, and adapted for informal income realities
Pillar 4: Credit Bureau Reporting, phased integration that builds toward financial inclusion
Pillar 5: Gender-Responsive Supervision, protect those most at risk, by design
Start where your capacity allows. Build from there.
Download the full regulatory intelligence report
If your jurisdiction is now considering its approach to BNPL regulation, we would welcome the conversation.
Contact Us: