Trust is the operating system for the next era of commerce 

The new FCA rules for Buy Now Pay Later aren’t the end of the story. They’re the first proof point in a much bigger shift.

The introduction of FCA regulation for BNPL providers will rightly be seen as a landmark moment for the sector. Much of the debate will focus on compliance, consumer protections and which firms are best prepared for the new regime. There is, however, a bigger story.

These new rules should not be viewed as the culmination of the BNPL journey. They are the first proof point in a much broader transition: one in which trust becomes the foundation of the next era of commerce.

The first era of fintech was defined by removing friction. Payments became faster, credit became more accessible and financial services became seamlessly embedded into everyday life. Success was measured by convenience. Now, we’re seeing regulation catch up, providing consumers with the protections they always deserved.

In parallel, we’re entering the dawn of a new era of fintech and commerce – one that presents a different challenge. AI agents that can search, compare and transact on a consumer’s behalf are no longer theoretical; they are already being built.

As AI evolves from an assistant into an autonomous agent – capable of discovering products, comparing prices, managing subscriptions and ultimately making purchases on a consumer’s behalf – convenience alone will no longer be enough. The defining question becomes whether consumers trust the systems making those decisions.

Trust begins with transparency

Our new Credit Confidence study has found that nearly a third of credit users find credit agreements difficult to understand, while only one in ten say their credit makes them feel genuinely in control. If consumers already struggle to understand the financial products they choose for themselves, how can they be expected to confidently delegate those choices to an AI agent? 

As financial decisions become increasingly automated, transparency, accountability and consumer protection become prerequisites for innovation, not obstacles to it. 

Viewed through this lens, the BNPL regulations coming into force this month are about far more than one payment product. They establish principles that will underpin the future of AI-enabled financial services. Innovation and regulation are not opposing forces; regulation creates the confidence that allows innovation to scale. 

Trust also creates intelligence

The most effective AI systems are built on rich, proprietary data, but that data cannot simply be collected. It must be earned. Consumers share more meaningful data only when they believe it will be used responsibly and deliver genuine value in return. 

Trust therefore becomes a strategic asset. It lets businesses build smarter payment experiences – ones that understand what customers want, delivering more personal outcomes. Over time, those same capabilities will underpin agentic commerce, where AI acts on a consumer’s behalf within parameters they understand and control. 

The trust flywheel

This creates a powerful flywheel. Transparency builds trust, trust encourages customers to share richer data, richer data enables more intelligent products, and better customer outcomes reinforce trust. Companies that understand this will be best placed to lead the next era of fintech innovation. 

For firms that have invested in governance, responsible lending, and transparency from the outset, the introduction of BNPL regulation is not a moment of disruption but one of validation.  

This is the ground Zilch was built on. As a fully FCA-regulated credit provider, these principles have shaped how we operate from day one. 

In the age of AI, trust is no longer just a regulatory goal – it is the operating system for commerce itself. 

The winners will not simply build the smartest AI. They will build the financial platforms that consumers trust enough to share their data with and, ultimately, trust enough to let AI act on their behalf.