Does Clearpay do a hard credit check UK? No, soft only

No. Clearpay’s help page says it runs a soft credit check on new customers, “not visible to other lenders and will not impact your credit score”, and that affordability assessments “may run soft credit checks”. Neither that page nor its privacy policy, read on 20 September 2026 and re-read on 16 October 2026, describes a hard credit check.

Updated 16 October 2026: Answer-first title and summary; opening now says No and records the 16 October re-read; FAQ added on whether other lenders can see the check.

What Clearpay says it checks, and when

Moment	Clearpay’s words	Not stated
New customer	“a soft credit check to help us assess your application”, guiding the “starting spend limit”	which agency; any figure
“Regular” affordability assessments, all customers	“may run soft credit checks”; may ask you to confirm “your income and expenses”	how often
Existing customers	“may use information from your credit report to review your spend limit”	what prompts a review
Decline, restrict or close	four examples: assessments say no further credit; “adverse information from your credit report”; repeated breach of Plan Terms; missed repayments	whether the list is complete (“for example”)
Reporting to CRAs	“Missed payments may be reported to Credit Reference Agencies”	which agency
Sharing with CRAs	“share your personal information with Credit Reference Agencies to help us make lending decisions”	which agency

The “which agency” gap closes in the privacy policy, which lists “credit reference agencies, such as TransUnion” among the parties it provides information to “to conduct a soft credit check”. “Such as” makes TransUnion an example. What Clearpay sends after a missed payment is in whether Clearpay reports to credit reference agencies; the purchase block behind a “restricted” account is in what happens if you miss a Clearpay payment.

Does Clearpay do a hard credit check in the UK under FCA rules?

The FCA’s page on regulating buy-now-pay-later, read 20 September 2026, lists “Clearpay (Clearpay Finance Ltd)” among firms registered for the temporary permissions regime; Clearpay’s footer reads “Deemed authorised and regulated by the Financial Conduct Authority for the purposes of the Temporary Permission regime”. That is not full authorisation, the gap described when the regime left firm status unclear.

The Handbook’s creditworthiness section, CONC 5.2A, last updated 4 November 2024, applies to “consumer credit lending” and does not mention BNPL in the rules read here; the table is a juxtaposition, not a finding that each line binds Clearpay.

FCA Handbook, CONC 5.2A	Clearpay’s published statement
5.2A.4R: “a reasonable assessment of the creditworthiness of a customer before” a regulated credit agreement or “significantly increasing a credit limit”	a soft check on application; credit report used “to review your spend limit”
5.2A.7R: information “where necessary from a credit reference agency”	information provided to CRAs “to conduct a soft credit check”
5.2A.10R: credit risk and “affordability risk”	“regular assessments for all customers of their affordability”

Neither rule read here says the assessment must be a hard search; the words are “reasonable” and “sufficient”, and whether a soft check meets them is the FCA’s question. What else changed on regulation day is in what changed on 15 July 2026.

Questions readers ask

Does Clearpay affect your credit score?

Not at sign-up, on the firm’s account: the help page says the new-customer check is soft and “will not impact your credit score”. Missed payments are the exception; the page says they “may be reported to Credit Reference Agencies” and “could affect your ability to access credit in future”.

Will a low credit score mean I get a lower Clearpay spend limit?

Clearpay says a credit score is “just one of the things we look at” and that payment history with Clearpay “will also be taken into account”. The help page prints no starting-limit figure; the amount “is estimated and therefore not guaranteed”. By how much a low score weighs is not stated.

Does Clearpay share my information with credit reference agencies?

The help page says missed payments may be reported to CRAs and that Clearpay “may also share your personal information with Credit Reference Agencies to help us make lending decisions”. The privacy policy names TransUnion as an example of the agencies it provides information to “to conduct a soft credit check”.

Can other lenders see a Clearpay credit check?

Clearpay’s credit-checks page says the soft check “is not visible to other lenders”; its “Will using Clearpay impact my credit score?” page, read on 16 October 2026, says it “is visible to other lenders”. Both say no score impact; neither explains the conflict.

Fin Watch is a publisher, not an authorised firm, and nothing above is advice. A help page can be rewritten without notice; the FCA Register, not a footer, is where a firm’s status is checked.