What the BNPL code of conduct asks of providers

You will be able to describe the protections the Singapore BNPL industry code gives you and their limits.

Ryan's friend Shu Fen told him not to worry about BNPL. "There are rules now," she said. "They can't let you owe too much, and the late fees are capped." She was partly right. There is a set of rules for BNPL providers in Singapore, and it does cover how much you can owe and how much you can be charged when you are late. But who wrote those rules, who has to follow them and what they leave out all change how much protection they actually give you.

An industry code, not a law

Singapore's BNPL code of conduct is an industry code, administered by the Singapore FinTech Association. It is a set of standards that BNPL providers agree to follow when they sign up to it. It is not an Act of Parliament, and it is not a set of MAS rules like the ones on unsecured credit from lesson 1.2, What lenders look for besides your report.

That difference matters in two ways. First, the code applies only to providers that have signed it. A BNPL option at a checkout may come from a signatory or from a provider that has not signed, and the checkout page will not necessarily tell you which. Second, the remedy if a signatory breaks the code runs through the industry body and its own processes, not through the courts in the way a legal duty would. The code's text on the Singapore FinTech Association website explains how complaints and breaches are handled.

None of that makes the code useless. It sets a floor for the providers that have signed, and many of the providers you are likely to see at Singapore checkouts are among them. It just means you should check rather than assume.

Limits on what you can owe

The code sets a limit on how much a user can owe a signatory before the provider has to carry out stronger checks on whether the user can afford more. Below that limit, a provider can let you use BNPL with lighter checks. Above it, the provider must look more closely at your finances before letting the balance grow.

The idea is that small amounts of BNPL can be offered quickly, and larger amounts get the kind of affordability check a bank would do. The current limit, and what the stronger checks involve, are set out in the code itself, so read the current version on the association's website rather than relying on a figure quoted in an article.

Notice what this limit does not do. It is a limit per provider. Owing up to the limit with one provider says nothing about what you owe another, and lesson 4.3, Why several small plans become one big problem, shows why that gap matters.

Limits on late fees

The code also limits the late fees a signatory can charge. The details, including how the limit is measured and over what period, are in the code. The practical effect is that one missed payment with a signatory cannot snowball into an unlimited pile of charges with that provider.

Again, the limit applies per provider. Three providers can each charge up to their own limit. Your own terms with each provider set out the actual late fee, which may be lower than the code allows. Read them for every app you use.

Suspension when you fall behind

Under the code, signatories must suspend users who fall behind on repayments. While you are suspended, you cannot make new BNPL purchases with that provider until you have caught up.

This is a real protection, because it stops one missed payment from turning into a growing balance with the same provider. It is easy to misread, though. Suspension stops new purchases. It does not cancel the debt. Every instalment you already owe is still due, along with any late fees, and the provider can still pursue it. It also doesn't stop you from using a different BNPL app, a credit card or a bank instalment plan to keep spending.

Checking your own providers

Shu Fen's version of the rules was close, but she missed the conditions. The limits apply to providers that have signed, they apply one provider at a time, and suspension stops the spending without touching the debt.

The Singapore FinTech Association publishes the code and a list of its signatories, and each provider publishes its own terms, including the late fee you would actually pay. Go to the association's website, find the current list, and check each BNPL app you use against it. Then open each app's terms and look up its late fee.

Check whether the BNPL providers you use have signed the code and note the late fee terms each one states.

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Junxiong-WFG Organisation is an authorised representative of AIA Financial Advisers Private Limited (Reg. No. 201715016G).