Five months after it was commissioned, and just three months after the call for input, the FCA has published the final report from the Woolard Review into change and innovation in the unsecured credit market. The Review concentrated on how regulation can better support a healthy unsecured lending market, taking into account the impact of COVID-19 on employment security and credit scores, changes in business models and new developments in unsecured lending, including the growth of unregulated products in retail and the workplace. Twenty-six recommendations for improvement are included in the final report. Key among them is that “[a]s a matter of urgency”, the FCA should work with HM Treasury (HMT) to ensure the necessary amendments to legislation are made to bring Buy-Now-Pay-Later (BNPL) products within the scope of consumer credit regulation.

We anticipate that many of our BNPL clients and other clients potentially impacted by these changes (including retailers) will want to respond to the upcoming consultations on this issue once they are published. We are ready to assist firms with assessing the proposals and responding to the FCA and HMT.  To read our full alert on the Woolard Review’s BNPL recommendations, please click here.


Kim is a Knowledge Lawyer within the Financial Services Regulatory group at Baker McKenzie. Her expertise covers both contentious and non-contentious regulatory matters across a wide range of sectors. She is particularly interested in issues relating to investigations and enforcement, vulnerable customers, regulatory reform and change, and the impact of Brexit on financial services regulation.