It was proposed to amend the bill on the regulation of installments

The Association of Participants in the Electronic Money and Money Transfer Market (AED) has proposed amendments to the bill on the regulation of BNPL services (Buy now pay later), which provide the opportunity to make purchases in installments. The letter of review was sent to Anatoly Aksakov, head of the Duma's financial market committee, and Izvestia reviewed its text on Tuesday, April 15.

The Association believes that in the current text of the draft law, regulatory requirements will create a serious administrative and financial burden on installment service operators. Thus, market participants will not only have to go through the procedures for inclusion in the relevant state registers, but also purchase, register and connect equipment for storing and transmitting data to the Interdepartmental Electronic Interaction System, government information systems and Credit Bureaus (BKI). They will also need to think through new client paths, including data transfer to the BCI and the identification process.

The AED notes that in order to implement all the measures provided for in the draft law, companies will need to increase their staff due to the shortage of staff with the necessary experience in building interaction with information systems. According to estimates by the AED, BNPL services will need at least 10 months of work and over 100 million rubles of investment to meet the conditions of the bill.

In this regard, the Association proposed to postpone the entry into force of the law for one year from the moment of its publication. This would allow operators to efficiently prepare for the implementation of new standards and ensure uninterrupted operation.

"Otherwise, installment payment operators will face the risk of suspension of operations due to the inability to meet the requirements of the law on time," the letter says.

The AED also proposed to increase the limit on installment purchases before transferring data to the BCI to 100 thousand rubles instead of 15 thousand rubles provided for by the current version of the bill. The organization believes that such a threshold will correspond to the current price increases for popular product categories. In addition, it is proposed to reduce the amount of data collected for transmission to the BCI and provide for more flexible administrative and technological mechanisms for customer identification.

Among other things, the Association considers it important to eliminate the ban on charging the first payment from the consumer before the full payment of the cost of the goods to the seller. This is due to the fact that in case of such delays, the installment service will become less convenient and more vulnerable to fraudulent actions. A similar risk is posed by the proposal to oblige installment service operators to notify the user 30 days before the date of cancellation of the contract, the letter says, according to the AED.

A bill proposing to introduce a limit of 15,000 rubles for the purchase of goods in installments without entering information into a credit history was submitted to the State Duma in early August last year. The document gives the Central Bank the authority to regulate the activities of BNPL services and maintain a register of operators. At the end of March, the bill was adopted in the first reading. From December 1, 2025, the maximum installment period will be six months, and from December 1, 2027, it will be limited to four months. The maximum amount of an installment purchase without transferring information to the credit history bureau is set at 15 thousand rubles, but it is planned to increase it to 50 thousand rubles, and the relevant amendments will be made by the second reading.

The bill also provides for a ban on the use of the installment service for foreign sellers and defines the status of the intermediary who will perform the functions of the operator of the installment service. This may be a legal entity registered in the form of an economic company, as well as a bank or microfinance organization. If none of the above organizations acts as an operator, the minimum amount of its capital should be at least 5 million rubles.

The bill was criticized by the Association of Banks of Russia, the Association of Travel Aggregators (ATAG), the Association of Online Trading Companies (AKIT), the National Financial Market Council (NSFR), as well as the Public Consumer Initiative (OPI) and Opora Russia.

Public activists believe that BNPL-instruments are fundamentally different from conventional loans: free installments are a socially significant service that is highly demanded by the population in its current form. Now a purchase can be made in a few clicks, and the need to send data to BKI will significantly complicate the product and turn installment payments into regular lending, alienating a significant part of the audience.