From July 2026, BNPL providers will fall under full FCA oversight. Most firms are already focused on tightening up their controls. But there’s a bigger issue being missed.

Preparing for regulation often means buying more data. Yet, what many BNPL providers don’t realise is just how much they’re already overpaying. In some cases, 50% more than their competitors, for exactly the same checks.

Pricing models are rarely transparent. Bundled products hide true costs. Legacy contracts go years without review. Plus, minimum spend clauses lock firms into inflated baselines.

In this blog, we look at what the FCA’s proposals mean for BNPL data obligations, where unnecessary cost is creeping in, and how benchmarking can help providers stay compliant without overspending.

What the FCA’s plans mean for data obligations

While the underlying principles come from existing credit rules, their application within this market requires a change in data strategy, governance, and evidencing.

Key points for firms preparing now:

• Affordability decisions must be backed by data
  Firms will need to show they’ve assessed a customer’s ability to repay using verifiable financial indicators. High-level credit scores or risk bands alone won’t meet the bar.
• Vulnerability insight must be built into the process
  The expectation is for earlier identification of risk. That requires more than flagging issues at arrears stage, including using data to detect signs of potential harm before problems escalate.
• Decisions must be explainable
  Oversight from the Financial Ombudsman Service will bring new accountability. Affordability and vulnerability assessments will need to hold up under external challenge.
• Consumer Duty elevates the standard
  This is less about additional rules and more about higher expectations. BNPL firms must act to deliver good outcomes, and that starts with choosing the right data inputs and applying them with discipline.
• Data cost management is now a compliance issue
  Many firms are increasing data spend to prepare. Without clear checks on price and value, this creates risk in itself, particularly where bundled services or legacy contracts are in place.

Managing compliance well depends on treating data procurement with the same rigour as any other regulated process. When pricing, utility and accountability are all on the table, firms make better decisions and avoid unnecessary cost.

Where BNPL firms overpay: Common data pricing traps

Many BNPL firms are paying more than necessary for services that haven’t been reviewed commercially, despite being central to compliance.

Three pricing traps come up time and again in benchmarking exercises:

Trap	What to watch for
Bundled checks that obscure true cost	Affordability, identity, and credit checks are often sold as a package. While convenient, many components offer limited value to BNPL firms. These bundles are typically priced for traditional lenders and include services that may not reflect a BNPL footprint.
Legacy contracts are misaligned with current operations	Pricing models often reflect historic volumes and risk strategies that no longer apply. Contracts are extended without review, leaving firms tied to outdated structures that don’t support today’s compliance needs.
Minimum spend thresholds that limit control	Volume-based deals can appear cost-effective but reduce flexibility. Fixed commitments make it harder to scale usage down or pivot to an alternative supplier, just when regulatory changes demand agility.

For many providers, these costs are accepted as part of doing business. But without a view of what comparable firms are paying, it’s difficult to challenge them, even when the value is unclear.

These pricing structures aren’t inherently flawed, the problem is how often they’re left untouched, even as the business and regulatory context changes.

Benchmarking as a smarter route to compliance

New regulation is forcing BNPL firms to rethink how they manage affordability and vulnerability. But while compliance processes are being reviewed, data costs often aren’t.

Benchmarking provides the missing context. It shows whether your pricing is fair, whether your services match your actual needs, and how your position compares to others in the market.

Here’s where it adds value:

1. Identify cost that doesn’t belong
   Across hundreds of credit data reviews, we regularly see pricing differences of 25-50% between firms with the same footprint. These differences often have nothing to do with scale, sector, or complexity. They come down to whether pricing has ever been benchmarked against the wider market.
2. Strengthen your negotiating position
   Credit bureaux know benchmarking data changes the conversation. When you can present verified pricing for the exact services you use, negotiations become more focused and harder to deflect.
3. Avoid defaulting to more data than needed
   In response to regulation, many firms opt for broader data coverage as a precaution. But more isn’t always better. Benchmarking helps you match data procurement to actual risk requirements, not assumptions.
4. Align procurement with compliance outcomes
   Affordability checks sit across risk, operations, compliance, and procurement. Benchmarking helps connect these functions, making sure commercial decisions support regulatory delivery, and vice versa.
5. Build flexibility into future contracts
   Once you understand what fair pricing and service look like, you’re in a stronger position to challenge rigid minimums, locked-in bundles or one-size-fits-all renewals. That’s especially important if your needs shift mid-contract.

Compliance and cost control aren’t competing priorities. But they do rely on the same thing: having a clear view of what you’re buying, what it’s worth, and how it compares. Benchmarking gives you that clarity and the evidence to act on it.

Compliance doesn’t need to come with a premium

Affordability data will soon be a regulated requirement. That’s a given.

But what you pay for that data, and whether the cost reflects your actual footprint, is still within your control.

There’s no need to change suppliers or wait for renewal. A benchmarking assessment can show whether your pricing holds up against the market, and whether your setup is doing what it should: supporting compliance, without overextending your budget.

Our benchmarking assessments reveal how your data pricing compares to firms with a similar footprint and where there’s room to improve. You won’t need to switch suppliers. You won’t need to commit. And you’ll have a clear, evidence-based view of whether your affordability data is fairly priced. Start your free assessment. It takes minutes.