China

Status

No steps taken to implement legislation to expressly regulate BNPL but this cannot be ruled out.

Is the country considering regulation?

BNPL services could be regulated as credit services under existing legislation in China.

Current state of regulation regarding BNPL?

BNPL as credit services are currently subject to regulations in China and appropriate licences are required to be obtained.

For non-bank financial institutions, the provision of consumer finance is regulated under a number of regulations, including the “Trial Administrative Measures on Consumer Finance Companies”.

For BNPL companies that do not provide credits to consumers but merely arrange for BNPL, they are currently not specifically regulated.

Outline the proposals to change regulation?

None – although if BNPL poses increasing risks to consumers due to lack of specific regulations, regulations may be passed.

What if any will be the consequences of BNPL legislation on merchants, brokers and consumers.

Existing requirements will continue to apply, but there may be enhanced requirements and other entities previously not regulated could be subject to additional regulations.