The Buy Now, Pay Later Compliance Checklist

Informational Materials: Promotional materials should inform consumers of their right to dispute charges. Provide clear instructions on initiating a dispute, which must be easily accessible on the BNPL provider’s website and other communication channels​

Consistent Messaging: Ensure this information is consistently included across all marketing platforms, including print materials and digital ads

Refund Information: All promotional materials should clearly explain the process for obtaining refunds for returned products or canceled services. This information should also be included in FAQs, brochures, and relevant web pages​

Prompt Processing: Ensure marketing messages communicate that refunds will be promptly credited to consumers' accounts in accordance with regulatory requirements

Complaint Identification: Have a system in place to quickly identify consumer complaints submitted directly to your organization, across social media platforms, and to regulators (like the Consumer Financial Protection Bureau)

Accessible Support for Consumers: Establish a clear and accessible procedure for handling consumer complaints. Provide multiple contact methods (e.g., phone, email, online form) and ensure these are prominently displayed in appropriate marketing materials

Timely Acknowledgements: Handle complaints promptly and provide written acknowledgments to consumers in a timely manner

Business History: Financial health, operational capabilities, and reputation in the industry

Customer Feedback: Customer reviews and ratings to gauge merchant’s service quality

Regulatory Compliance: Ensure the merchant has processes in place to comply with relevant laws and regulations, including consumer protection and data privacy laws

Enforcement Actions: Check if the merchant was involved in any previous enforcement actions or lawsuits

Website: Ensure the merchant’s website is legitimate

Social Media Presence: Make sure the merchant is posting appropriate content and advertising what they sell (i.e. not selling any items prohibited by your brand)

Merchant websites and promotions

Email marketing campaigns

Social media platforms (Facebook, X, LinkedIn, TikTok, YouTube, etc.)

Paid search advertising (Google Ads, Bing Ads, etc.)

Display advertising (banner ads, pop-ups, etc.)

Direct mail campaigns

Messaging channels (SMS, messages, chat boxes, push notifications, etc)

Affiliate marketing programs

Referral marketing program

Notifying the individual of the violation 

Removal or remediation of non-compliant content

Documenting instances of non-compliance and remediation

Determining appropriate disciplinary actions for individuals or third parties who repeatedly engage in non-compliant behavior

Automatic discovery and ongoing monitoring across marketing channels, merchants, and third parties

Ready-to-use and expert-built rulebooks designed to identify potential compliance violations to monitor content against

A  centralized workflow that tracks activities across both internal departments and external partners, merchants, or third parties

Detailed reporting and analytics for compliance and performance

Archived history from discovery through remediation for any audit situation

Opportunity for scale that makes it easy to add additional marketing channels for review and monitoring