The temporary permissions regime leaves a visible gap in firm status
A transitional regime is a sensible way to regulate a live market. It also means the register entry a consumer looks up does not mean what they assume it means.
Transitional regimes exist because the alternative is worse. Requiring every firm in a live consumer market to be fully authorised on day one would either shut down products people are mid-way through repaying, or produce an authorisation process too shallow to mean anything.
The FCA’s temporary permissions regime for buy-now-pay-later is the sensible answer to that problem. It also creates a period in which the thing a consumer checks does not tell them what they think it does.
The distinction
A firm with full authorisation has been assessed against the FCA’s threshold conditions and granted permission for specified regulated activities.
A firm with a temporary permission is registered to continue operating while it applies. Registration is not the outcome of the same assessment. Both firms appear on the register; the entries mean different things.
Neither position is a mark of quality, and we would not suggest a firm with temporary permission is doing anything improper — it is doing exactly what the regime intends. The point is narrower: a consumer checking “are they FCA registered”, finding a result, and stopping there has not learned what they set out to learn.
The complaints-reporting wrinkle
There is a second gap worth recording. Firms operating under the temporary regime are not required to submit complaints returns until they are fully authorised, at which point the earlier complaints must be included in the first return.
The data is therefore not lost. It is deferred. But for the transitional period, published complaints data will not cover the whole market, and anyone comparing firms on complaint volumes during this window is comparing an incomplete picture. That is a limitation of the data rather than a criticism of any firm, and it is exactly the sort of thing a watchdog column exists to point out.
What a consumer can actually do
Look the firm up on the FCA Register. Read what the entry says, including which permissions it covers and whether it is a temporary permission. Note that permissions are activity-specific, and that a group may contain several entities with different permissions — the one you are contracting with is the one that matters.
Then read the firm’s own terms for what you actually want to know: fees, credit reporting, and the complaints route.
Fin Watch is a publisher. We are not authorised or regulated by the Financial Conduct Authority, we do not assert any firm’s regulatory permissions, and nothing here is financial advice.