Regulating BNPL (Klarna, Clearpay et al.) in the UK, or maybe not?

There has also been some talk about FCA regulating “Earned wage access” scheme like Wagestream (some HCM systems offer similar capability natively as well, e.g. Ceridian Dayforce Wallet), for similar reasons to BNPL. (Other retail credit has long been regulated by FCA and predecessors).

There is indeed a moral hazard for employers that Earned wage access could result in monthly paid employees having 0 paycheque at the end of the month, even if there a limit on how much they can draw early. For example an unexpected screwup in salary deductions for tax or other unexpected deductions from wages.

I believe BNPL’s first lever that is under threat is advertising. Are these companies ensuring that partners are properly being advertised? The sector is new but reminds me of a digital version of lay-bye.