Advancements in the world of fintech have fundamentally reshaped consumer behaviour through the rise of flexible payment methods, driven by surging technological developments. In turn, these shifts have necessitated substantial regulatory initiatives aimed at accommodating and governing the evolving financial ecosystem.
A prominent example is "buy now pay later" arrangements (BNPLs) which the European Banking Authority ("EBA") has recognised as a growing trend across the EU.
As flexible payment alternatives, BNPLs are a form of short-term, unsecured consumer lending by third-party entities, where a consumer is allowed to purchase goods now and pay the merchant at a future date, either in instalments or as a lump sum payment. Generally, BNPL arrangements have three parties: (i) the customer who is acquiring the goods, (ii) the online merchant who is providing the goods, and (iii) the platform which is the entity providing the finance. The platform will pay the merchant, and in turn
