CAP says that Buy Now, Pay Later (BNPL) services, which enable payments to be deferred for a short period of time, have become increasingly available to customers at the checkout of online retailers. Accordingly, CAP has published new guidance on advertising delayed payment services (broadcast and non-broadcast), specifically relating to services that are not regulated by the Financial Conduct Authority (FCA).

Although they are not a new form of payment or credit, the easy accessibility of BNPL services, built as they are into online checkouts, and their popularity with younger consumers, means that potential customers may be less aware that deferring payment using these services is a type of debt. As such, customers may be less likely to fully appreciate possibilities of late payment fees and, potentially, referral to debt collection agencies and any subsequent impact on credit scores.

The guidance is intended to prevent ads for these services from misleading consumers. Most notably, it advises advertisers on how to ensure consumers understand that the service being offered comprises a form of credit.

CAP expects all advertisers to act swiftly to amend their advertising where necessary. However, it will be mindful that amending practices might take longer for some media types, especially those that integrate with companies’ internal payment systems. In those circumstances, CAP is giving advertisers until 2 March 2021 to resolve matters informally and adjust to the new guidance. To read CAP’s announcement in full and for a link to the guidance, click here.