
Agentic commerce in UK retail: An unresolved liability question
UK merchants expect agentic commerce to grow rapidly, but uncertainty around liability, fraud, and standards is slowing readiness.
23 September 2025
by Payments Intelligence
What is this article about?
The current state of BNPL, its stabilisation at 5% of global e-commerce, and the factors shaping future growth.
Why is it important?
BNPL’s trajectory will influence global payments, regulation, and consumer credit behaviour.
What’s next?
Expansion in emerging markets, vertical diversification, tighter regulation, and integration with traditional finance.
Buy now, pay later (BNPL) holds 5% of global e-commerce transaction value in 2024, with projections showing this share will be maintained through 2030. While BNPL growth has matured in developed markets, payment leaders face a landscape where regulatory pressures, demographic shifts, and geographic expansion will determine the sector’s trajectory over the next decade.
BNPL has moved from disruption to mainstream, but adoption remains uneven. Digital wallets dominate at 53% of global e-commerce payments, with credit cards holding 20%, whilst BNPL sits at 5%—a position it’s expected to maintain through 2030. This plateau masks regional variations and emerging growth vectors that payment leaders must navigate as they build their strategies for further expansion.
The geographic distribution of BNPL adoption reveals a market in different stages of development. Eight of the top ten global BNPL markets are located in northwestern Europe, with Sweden achieving 23% market share and Germany reaching 20%—approximately ten times higher than the global average. This concentration shows not just early adoption but sophisticated consumer acceptance and regulatory frameworks that have allowed the sector to develop.
European markets show significantly higher BNPL penetration at 8% compared to Asia-Pacific at 4%, Latin America at 1%, and the Middle East/Africa at 2%. In mature markets like Sweden and Germany, providers face market saturation concerns, whilst emerging markets present untapped potential but require different approaches to credit assessment, regulatory compliance, and consumer education.
Regional consolidation trends are emerging as regulatory scrutiny increases globally, with mid-tier players consolidating with larger providers to achieve scale and compliance. For payment leaders, this suggests a bifurcated strategy: defending market share in developed regions whilst scaling rapidly in emerging markets before competitors establish dominance.
The demographic profile of BNPL users reveals both current momentum and future growth potential. Eighty-two percent of Gen Z and 77% of millennials express interest in using BNPL services, compared to significantly lower adoption rates among older generations. In the US, adults with low or middle incomes were more likely to use BNPL than those with higher incomes, with only 8% of respondents earning $100,000 or more using the service, compared to 14% across other income levels.
A forecast 46% of Gen Z consumers will use a BNPL option in 2025, nearly doubling their 2023 participation. However, consumers who use BNPL tend to have a riskier credit profile: they are typically younger and less educated, with higher debt burdens and lower credit scores.
As Gen Z enters their peak earning years over the next decade, their ingrained preference for flexible payment options will likely drive broader market expansion. However, this growth must be balanced against increasing regulatory scrutiny of lending to vulnerable populations and growing concerns about delinquency.
BNPL adoption varies significantly by product category, revealing clear expansion pathways. Apparel dominates BNPL usage in the US, with $12.43 billion in transaction volume in 2021, followed by personal effects at $2.76 billion and mass market retail at $2.65 billion. 28% of travel payment leaders plan to implement BNPL solutions within the next 12 months, indicating significant vertical expansion opportunities.
Healthcare has emerged as a fastest growing vertical for BNPL, with Sunbit partnering with roughly 7,300 healthcare providers to fund. This expansion beyond discretionary retail purchases into essential services represents a fundamental shift in BNPL’s utility and market positioning.
For payment leaders, this vertical diversification offers multiple growth avenues but requires different risk models, regulatory approaches, and consumer protection measures. Healthcare BNPL, for instance, involves different regulatory frameworks than retail purchases, whilst travel payments require sophisticated fraud prevention and customer service capabilities.
The UK’s regulatory landscape is undergoing transformation as the Financial Conduct Authority (FCA) advances towards comprehensive BNPL regulation. However, the regulatory framework remains in active consultation until late September 2025, with implementation not scheduled until July 2026. This extended timeline reflects the complexity of creating bespoke rules for a rapidly evolving sector.
The FCA’s consultation, which closes on 26 September 2025, proposes disclosure requirements, affordability assessments, and consumer protection measures that will reshape competitive dynamics. UK BNPL providers are preparing for compliance obligations whilst attempting to maintain the seamless customer experience that drove initial adoption. The delayed implementation provides additional time for industry adaptation but creates ongoing regulatory uncertainty.
This measured approach contrasts sharply with the upheaval experienced in the US, where the Consumer Financial Protection Bureau (CFPB) faced an unprecedented operational shutdown in February 2025. Acting Director Russell Vought ordered staff to “cease all supervision and examination activity” and closed the agency’s headquarters, effectively halting consumer protection enforcement. Although federal courts later ordered the CFPB to resume operations in March 2025, the disruption created significant regulatory uncertainty across American financial services.
The CFPB’s turbulent period included the rescission of its May 2024 interpretive rule that had classified certain BNPL products as “credit cards” under Regulation Z. This rule, which would have extended credit card protections to pay-in-four BNPL products, was abandoned following industry challenges and the change in federal administration. The policy reversal eliminates potential dispute resolution requirements and periodic statement obligations for BNPL providers.
This federal regulatory retreat has indeed created a patchwork of state-level initiatives. California, New York, and Massachusetts continue evaluating bespoke disclosure and licensing rules, adding operational complexity for nationwide operators, whilst federal oversight remains diminished.
The divergent regulatory approaches create strategic challenges for international BNPL providers. Whilst the UK advances towards comprehensive oversight with clear implementation timelines, the US market remains fragmented despite previous federal efforts to standardise consumer protections.
50% of Americans still support stronger regulations—whether clearer disclosures, capping fees, or stricter credit score checks—suggesting regulatory pressure may return regardless of current federal policy. The UK’s proactive regulatory stance positions British consumers with stronger protections but challenges providers to demonstrate compliance whilst maintaining growth trajectories in an increasingly competitive marketplace.
Rising delinquency rates present perhaps the greatest near-term challenge to BNPL expansion. UK research by the Centre for Financial Capability in 2024 found that younger BNPL users were more likely to have missed payments than other age groups, with 34% of consumers aged 18-24 being charged late fees compared to other demographics.
Nearly a quarter (22%) of UK BNPL users have missed one or more repayments in the six months to December 2023, with around two-thirds of those missing payments twice or more. More than a quarter of those who missed repayments saw their credit scores decline or were contacted by debt collectors. These figures vary significantly by provider, suggesting that underwriting standards and customer selection remain key differentiators in the market.
The credit risk challenge is particularly acute given BNPL’s traditional zero-interest model. Offering interest-free BNPL services excessively may shift existing customers away from payment options that cost merchants less to accept, potentially raising retail prices for everyone.
Despite these challenges, several clear growth vectors are emerging:
BNPL’s stabilisation at 5% of global e-commerce spend signals not a decline but a shift from rapid growth to a disciplined strategy. For payments leaders, the task is now to allocate resources with precision:
The next phase of BNPL will be won not by first-mover advantage but by leaders who can convince boards, secure budget, and shape products that respond to regulatory, demographic and geographic realities. Success will depend on acting decisively now, with strategies tailored to both saturation in developed economies and expansion potential in underpenetrated regions.

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