Deferred payments (BNPL) under control- new regulations coming in 2026

The dynamic growth of deferred payment services (BNPL –buy now, pay later) in Poland is increasingly attracting the attention of regulators. A draft act regulating consumer credit -which would explicitly cover BNPL services -may be adopted by the Council of Ministers as early as the first quarter of 2026.

This would place this form of financing under a uniform legal regime, something that has so far been lacking.

BNPL is growing in strength- dynamic development and a lack of consistent regulations

At present, deferred payments, despite their scale and rapidly growing popularity, operate outside the traditional regulatory framework governing consumer credit. Meanwhile, as market data show, the sector is expanding at a very fast pace.

By theend of October 2025, the value of BNPL transactions had already exceeded the total recorded for the whole of 2024 and is likely to reach approximately PLN 14 billion, compared with PLN 10.7 billion a year earlier. More than 70% of Polish e-commerce retailers currently offer deferred payment solutions, and Polish consumers use them far more frequently than their counterparts in Western Europe.

However, the growing scale of the market raises questions about consumer protection and regulatory consistency. The aim of the proposed legislation is to streamline the existing legal framework, under which consumer credit may currently be granted on the basis of three different legal acts.

The new regulation is intended to introduce a clear rule whereby all consumer credit -including deferred payment products -will be governed by a single statute and subject to uniform principles.

New BNPL regulations- consumer protection and changes for providers

Importantly, the draft law represents a shift in the regulatory paradigm. While the protection of deposits as a source of credit funding has traditionally been a key focus, the new provisions place primary emphasis on protecting borrowers against excessive indebtedness.

For BNPL providers, this will mean the need to align their business models with requirements familiar from the consumer credit market, including those relating to creditworthiness assessments and information obligations.

At the same time, the BNPL sector continues to develop rapidly from a technological perspective. Experts point to increasing integration of deferred payment solutions with artificial intelligence-based tools, greater flexibility of repayment plans, and expansion into offline sales channels.

As a result, the planned regulations may enter into force at a time of peak market dynamism. If the legislative timetable is maintained, Parliament could adopt the new rules in the first half of 2026, marking a significant change in the legal environment for one of the fastest-growing segments of the Polish financial market.

New BNPL regulations represent a fundamental change for deferred payment providers

If you want to prepare your company for the entry into force of uniform consumer credit regulations, contact the Dudkowiak & Putyra team. We will help you adapt your business model, compliance procedures, and creditworthiness assessment to the new legal requirements.