Digital and AI-era BNPL disclosures

Determine how to design disclosures for Buy Now, Pay Later products in digital and AI-mediated environments.

Background

The paper identifies a regulatory gap arising because existing disclosure regimes were developed before BNPL products and digital interfaces became widespread. It explicitly characterizes the design of disclosures for digital and AI contexts as unresolved, with the issue complicated by new forms of financial-product advertising and the role of celebrity influencers.

References

There remains an open question on how to design disclosures for the digital and AI world. The existing disclosure regimes did not have products such as BNPL or digital interfaces in mind.

— Buy Now, Pay Later: Academic Insights and Open Policy Questions  (2609.09323 - Guttman-Kenney et al., 8 Sep 2026) in Section VIII, “Concluding Thoughts”