New York Enacts Landmark Buy Now Pay Later Regulation Amid Federal Regulatory Recalibration

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As part of its FY 2026 budget, New York has enacted legislation to regulate Buy Now, Pay Later (BNPL) products and providers.

In addition to creating a new licensing regime, the legislation mandates that the New York Department of Financial Services (NYDFS) superintendent promulgate rules to establish capital adequacy requirements and maximum allowable interest, charges, and fees.

The law also empowers the superintendent to promulgate other rules for its implementation.

The new law’s effective date hinges on NYDFS rulemaking, set to occur six months after promulgation of the implementing rules.

In a significant consumer protection move, New York has enacted legislation within its FY 2026 budget to regulate BNPL products — installment-style credit often offered at the poin