When Deferred Payment Credit (DPC) came under FCA regulation in July 2026, lenders faced a new challenge: meeting requirements for proportionate affordability assessments without unnecessarily restricting access to credit.
Zopa for Business demonstrated that meeting these requirements does not have to come at the expense of approval rates. By incorporating Infact's sophisticated expenditure estimates into its affordability assessments, Zopa maintained robust approval rates while accounting for customers' individual financial circumstances, without adding friction at checkout.
Deferred Payment Credit (DPC), commonly known as Buy Now Pay Later, has become an established part of the UK's consumer credit landscape. According to FCA figures cited in Zopa's DPC whitepaper, lending exceeded £13 billion in 2024, with 10.9 million UK adults using DPC in the 12 months to May 2024.
Since 15 July 2026, third-party DPC lending has been subject to FCA regulation, including requirements for proportionate affordability assessments.
For Zopa, the challenge was meeting these requirements while maintaining approval rates and a seamless checkout experience.
One of the difficulties lies in how essential expenditure is estimated. Traditional affordability assessments often rely on household averages derived from Office for National Statistics (ONS) data. While useful as a benchmark, these averages can misrepresent the financial circumstances of customers whose spending differs from the norm.
This creates two potential risks:
For Zopa, maintaining responsible lending standards meant ensuring its affordability assessments could better reflect individual circumstances, rather than relying too heavily on averages.
Zopa for Business uses Infact's Affordability product as part of its multi-layered approach to affordability assessments.
Infact's proprietary models use information already provided during the application to generate more individualised estimates of essential expenditure across categories including housing, food, energy, transport and childcare.
This gives Zopa a more nuanced view of customers' financial circumstances, supporting:
"An average tells you what a typical household spends. It tells you very little about the person at the checkout. Zopa for Business assesses each customer on their own numbers, and that is how they met the new DPC requirements without turning away people who could comfortably afford to pay."
James Bryce-Lind, VP Commercial, Infact
By bringing greater precision to expenditure modelling, Infact supports Zopa in making proportionate affordability assessments that balance responsible lending with commercial performance.
Following the introduction of DPC regulation, Zopa for Business maintained robust approval rates, demonstrating that stronger affordability requirements don't necessarily have to result in more declines.
"Better affordability checks don't have to mean more declines. Using Infact's data, we assessed each customer on their own outgoings, and our approval rates have remained robust after DPC was introduced."
Tim Russell, General Manager, Retail Finance and Payments, Zopa for Business
For Zopa and its merchant partners, this is a meaningful outcome. More individualised expenditure estimates support proportionate affordability assessments without unnecessarily restricting access to credit or introducing friction into the customer journey.
Zopa's experience demonstrates how lenders can navigate evolving regulatory requirements while protecting customers and maintaining commercial performance.
Zopa's experience highlights the value of moving beyond broad household averages to better reflect customers' individual financial circumstances.
With more sophisticated expenditure estimates, lenders can support responsible lending, preserve access to affordable credit and maintain an efficient customer experience, even as regulatory expectations evolve.
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