We, along with our peers, have been advocating for the regulation of BNPL products for years, and keenly await the implementation of the new legislative regime, which will reduce the risk of people being signed up to unaffordable BNPL debts that leave them worse off. However, we are extremely disappointed to see the changes made in the Draft Regulations to the cap on default (late) fees. For certain BNPL models (notably, the model used by Afterpay), the permitted annual cap on late fees has more than doubled the previous proposal.