Klarna and Clearpay after regulation day, assessed on what each now says about its own permission

Klarna’s own terms index states the fact plainly: “At 00:00 on 15th July 2026 BNPL (also called deferred payment credit) became regulated in the UK.” Both Klarna and Clearpay reissued their governing documents that day. This desk read both indexes on 6 September 2026 and assesses them on one question — not which is cheaper, but what each now tells a shopper about the rules it trades under.

What the two documents say on their face

Two BNPL documents, read on 6 September 2026

Clearpay, legal entity named	Clearpay Finance Limited, company number 05198026
Clearpay, permission stated	'Deemed authorised' under the Temporary Permission regime
Clearpay, terms last updated	15 July 2026; prior version effective until 14 July 2026
Klarna, index structure	Split into agreements made after, and before, regulation day
Klarna, permission stated	Not on the terms index we read
Clearpay late fee, disclosed	£6 per late instalment; a further £6 after 7 days over £24
Clearpay late-fee cap, over £24	The lower of £24 or 25% of the purchase price

Clearpay states its status, and states it early

The Clearpay Terms of Service carry “Last Updated: 15 July 2026”, and put the firm’s regulatory position in the first numbered clause, before eligibility, before fees. The wording is exact and worth quoting as written: Clearpay Finance Limited “is deemed authorised and regulated by the Financial Conduct Authority for the purposes of the Temporary Permission regime for Regulated Deferred Payment Credit.” The same clause explains what that regime is — one that “allows firms to carry on deferred payment credit activities while seeking full authorisation.”

That is candid drafting, and rarer than it should be. It is also the sentence a hurried reader will misread. Deemed authorised is a real permission and a real perimeter; it is not the same thing as authorised. It is a transitional status, held, in the document’s own words, “while seeking full authorisation” — and the document says so itself rather than burying it in a footer. Credit where it is owed: the firm names its company number, its registered office at 101 New Cavendish Street, and its regime, in the same breath.

Klarna sorts by date, and that is the useful part

Klarna’s UK terms index solves a different problem, and solves it well. It lists a Pay Later in 30 Days Deferred Payment Agreement and a Pay in 3 instalments Deferred Payment Agreement under the heading “For agreements made after regulation day”, and the older Pay Later in 30 days and Pay in 3 instalments documents under “For agreements made before regulation day”.

That split matters more than it looks. A shopper who opened a plan in May 2026 and another in August is governed by two different contracts, and until 15 July nobody had to sort them. Klarna has done the sorting on the index page, in words a non-lawyer can act on — where most firms would have replaced the old page and left the customer guessing which document was live when they signed.

What the index does not do is state Klarna’s own permission. No such statement appeared on the index page we read — we confine that to that page, since a terms index is not a disclosure page and the statement may sit elsewhere on the site. The point stands regardless: a reader just told, at the top of the page, that their product became regulated in July is at exactly the moment of wanting to know by whom, and the page moves straight to a list of PDFs.

Where both documents stop

Neither index settles what regulation actually buys the borrower. The change of perimeter is stated; the consequences are not, and this desk will not fill that gap with a summary it has not read in a primary source. Nor does either page tell you whether the firm holds today the permission it held in July — a transitional regime is transitional by design, and every status recorded here is a status as at 6 September 2026.

Clearpay’s fee disclosure, at least, is unambiguous and sits in the same document: £6 for a late instalment, a further £6 if an instalment over £24 is still unpaid seven days later, capped at the lower of £24 or a quarter of the purchase price, with nothing charged on orders under £24. Missed payments, it says, may be passed to a debt collection agency and reported to credit reference agencies. Our assessment of rent-reporting terms met the same asymmetry: the adverse consequence is disclosed precisely, the benefit vaguely.

The disclosure ledger

Pros

Clearpay names its regime in clause 1, before eligibility or fees
Clearpay quotes its status in full, not as the word 'authorised' alone
Clearpay names entity, company number and registered office together
Klarna's index separates post-regulation-day from pre-regulation-day contracts
Klarna states the commencement moment precisely: 00:00 on 15 July 2026
Clearpay's late fees and their cap are stated in figures, in the same document

Cons

'Deemed authorised' will read to most shoppers as ordinary authorisation
Clearpay's status is transitional, and the page cannot say how long it lasts
No permission statement appeared on the Klarna terms index we read, where a reader would look
Neither index explains what regulation changes for the borrower in practice
Klarna's split leaves the shopper to remember which month they signed
Both are indexes of PDFs; the terms that bind you are one click further down

Verdict

If you take one thing from either page, take the exact wording. “Deemed authorised … for the purposes of the Temporary Permission regime” is not a synonym for authorised, and a firm that writes it out in full is telling you something a footer would have hidden.

Loan Herald lends nothing, brokers nothing, is nobody’s appointed representative and is not authorised or regulated by the Financial Conduct Authority. We quote what these firms publish about themselves; we do not confirm it. Check either firm’s current permission yourself on the FCA’s Financial Services Register rather than taking a terms page’s word for it, or ours — a transitional permission is precisely the kind that changes. None of this is advice or encouragement to use deferred payment credit. And if instalments are becoming hard to meet, free non-commercial help exists at Citizens Advice, StepChange and National Debtline.