Regulatory tracker

    BNPL Furnishing Compliance

    Live tracker for Buy Now, Pay Later credit-reporting standards. This space moves fast — CFPB rules, FICO scoring updates, and bureau intake specs change on a quarterly cadence. We update this page whenever a material change ships.

    Last reviewed: 2026-05-18

    Bureau positions (May 2026)

    BureauAccepts P4?ChannelSchema notesScore impact
    EquifaxYes (since Feb 2022)Standard Metro 2 with business_industry_code (BIC) taggingReported as Installment ('I'/'18') or Revolving ('R'/'10'/'12'). BIC value confirmed per furnisher onboarding.Visible to lenders. FICO Score 10 BNPL explicitly consumes it.
    ExperianYes (since Apr 2025, Affirm-led)Dedicated 'Buy Now, Pay Later Bureau' specialty file (NOT Metro 2 fixed-width)Today monthly aggregated; biweekly cadence planned. Vendor intake spec gated.Sequestered from FICO 8 / VantageScore 3. Visible to opt-in pull users.
    TransUnionYes (since Feb 2022)Metro 2 with BNPL flag in reserved byte position + specialty filterTwo biweekly payments combined to a monthly amount; term expressed in months (rounded up).Tagged out of core scores by default.

    Regulatory timeline

    1. 2025-05-12

      CFPB formally withdrew its May 2024 BNPL interpretive rule (Reg Z 'credit card' classification of Pay-in-4). Reg Z dispute/refund/statement obligations are no longer enforced against P4 lenders.

      Source: CFPB withdrawal notice

    2. 2025-06

      FICO Score 10 BNPL and 10 T BNPL announced. New explicit P4 aggregation logic — multiple Pay-in-4 loans are composited into a single utilization signal, recognizing the 'tradeline explosion' problem.

      Source: FICO

    3. 2025-Fall

      FICO Score 10 BNPL goes GA. Lenders begin opting in.

      Source: FICO

    4. 2025-11

      Senate Banking Committee letter to Klarna pressuring P4 lenders to begin furnishing. Klarna and Afterpay still publicly decline to furnish.

      Source: U.S. Senate Banking Committee

    5. 2026-02

      Congressional Research Service Report R48858 published — documents the post-withdrawal policy vacuum and notes that federal preemption of state P4 laws (NY DFS, CA DFPI, CT, VA) is unsettled.

      Source: CRS R48858

    Non-furnishing P4 lenders

    Two of the largest U.S. Pay-in-4 brands still refuse to furnish in 2026. We track posture changes here because the moment they switch on furnishing is the moment our market expands materially.

    • Klarna

      Publicly declines to furnish to U.S. bureaus as of 2026. Has begun limited furnishing in EU markets.

    • Afterpay

      Publicly declines to furnish. Has stated 'BNPL is not credit' to consumer-facing audiences.

    How Metro 2 by Switch Labs

    handles BNPL today

    • Native BNPL ingest API — POST your per-purchase loans + biweekly installment schedule, no Metro-2-aware client work required.
    • Configurable rollup policy per furnisher per bureau: per_loan (Affirm/Experian-style) by default; aggregate variants available as opt-ins.
    • Biweekly → monthly Payment History Profile translator with full audit log (each rule firing recorded for §623(b) disputes).
    • FCRA-safe DOFD derivation: defaults to monthly_bucket (+30 days). The legacy strict reading (day after missed installment) is blocked at the database level for standard Metro 2 output.
    • Equifax route is live today via the BNPL portfolio template; TransUnion tagged-Metro-2 and Experian BNPL Bureau specialty intake are in development.

    Spec deferred — Phase 3

    The Experian BNPL Bureau intake spec and the TransUnion BNPL flag byte position are both gated behind vendor onboarding. Build is paused on those routes until the specs land. Equifax BNPL via the standard Metro 2 + BIC path is live and shippable for any customer onboarded today.

    BNPL Furnishing Compliance Tracker — Metro 2 by Switch Labs