The expansion of the Internet and technological advancements has led to the increasing use of platforms that provide services similar to those offered by banks, including the extension of credit through “Buy Now, Pay Later” (BNPL) arrangements. This development reflects significant changes in consumer financing patterns and payment methods while giving rise to new legal and regulatory challenges. Much of the existing literature in banking law has focused on the analysis of traditional contracts and financial arrangements. Using a descriptive-analytical approach and relying on library-based sources, this article examines the implications of the emergence and growing adoption of BNPL services for the banking system and investigates whether Iranian law provides a comprehensive and coherent regulatory framework governing such services.
The findings indicate that BNPL arrangements involve a multi-layered contractual structure among consumers, merchants, and BNPL service providers. The principal challenges associated with these services include the incorporation of unfair contractual terms, lack of transparency regarding fees and charges imposed on consumers, legal risks arising from the accumulation of debt across multiple BNPL providers, issues relating to collateral requirements, credit assessment mechanisms, and violations of consumer privacy. The study concludes that effective regulation of BNPL services in Iran requires an integrated regulatory approach under which the Central Bank is responsible for financial and prudential supervision, while a specialized consumer protection authority, alongside the Central Bank, oversees contractual transparency, the protection of consumer rights, and the handling of consumer complaints.