New decree bars real estate from third-party BNPL plans

New regulations will prohibit real estate from being included in third-party Buy Now, Pay Later (BNPL) schemes, effective January 1, 2027. This change stems from the President's recent signing of the "Steps to improve buy now pay later (BNPL) services for the public" Decree.

The decree explicitly states that real estate, along with other property legally restricted or withdrawn from circulation, cannot be sold using BNPL services.

The Ministry of Justice has since provided further clarification on this particular rule. The ministry explained that subclause "e" of clause 3 of the decree prevents licensed BNPL operators—meaning intermediary companies—from offering real estate as a BNPL product. However, the ministry emphasized that this does not stop a developer from directly selling a home they constructed to a buyer on a BNPL basis. This is because subclause "a" of clause 3 specifically excludes direct sales from a seller to a consumer from the definition of BNPL payment services. Consequently, buyers can continue to purchase housing directly from developers using BNPL arrangements, as the decree does not forbid direct transactions between developers and buyers, according to the ministry.

Upon its implementation, BNPL operators will be mandated to register in a specialized registry and will be supervised by the Central Bank, which will establish precise requirements for their contracts, markups, and commissions.