Three regulators, on three continents, moved on the same underlying question this quarter: who has to answer to a banking supervisor for holding or lending someone else's money. India's central bank let a class of quiet, back-office lenders opt out of registration. Britain's regulator brought a long-unregulated consumer credit product under full supervision for the first time. And a core banking technology vendor in the United States built its answer directly into the plumbing, keeping customer money on a chartered bank's own books no matter how consumer-facing the software around it gets.
RBI opens an exit for NBFCs that don't touch public money
The Reserve Bank of India issued the final Non-Banking Financial Companies (Registration, Exemptions and Framework for Scale Based Regulation) Amendment Directions, 2026 on April 29, 2026. The new framework took effect July 1, 2026 (Mondaq, 2026; Lexology, 2026). It splits non-banking financial companies into two registered tiers, Type I and Type II, and creates a third, unregistered category for entities that neither raise public funds nor deal directly with customers.
An NBFC qualifies as an "Unregistered Type I NBFC" if its asset base sits below ₹1,000 crore. It must also take no public funds and have no customer interface (Corporate Professionals, 2026). In practice, that describes group-financing or holding-company vehicles rather than retail lenders. Entities that already hold a Certificate of Registration and meet that description can apply through the RBI's PRAVAAH portal to give it up. The application requires three years of audited financials and a statutory auditor's certificate confirming the company takes no public money and serves no customers directly (CorpLawUpdates.in, 2026).
The logic is straightforward. An NBFC that never touches a depositor or a retail borrower carries little of the systemic or consumer risk that registration exists to manage. Freeing it from that oversight lets RBI spend its supervisory attention on the companies that do carry that risk, the Type II NBFCs with public funds or a customer interface, regardless of size. Secondary legal commentary disagrees on the exact date the one-time surrender window closes, some citing September 30, 2026 and others December 31, 2026, so any NBFC relying on it should confirm the deadline directly with RBI before filing.
FCA brings Buy Now, Pay Later inside the perimeter
Britain moved in the opposite direction. The Financial Conduct Authority published its final rules for Deferred Payment Credit, the interest-free installment product widely known as buy now, pay later, in Policy Statement PS26/1 on February 11, 2026 (FCA, 2026). The rules took effect on July 15, 2026, a date the FCA calls Regulation Day.
From that date, DPC lenders must give borrowers clear pre-contractual information, run full creditworthiness and affordability checks before lending, and notify customers who miss a payment (FCA, 2026). Borrowers can now also complain to the Financial Ombudsman Service if something goes wrong, a route that did not exist for this product before. Firms already offering DPC as of July 15, 2025 could register for a temporary permissions regime between May 15 and July 1, 2026, then had six months from Regulation Day to secure full FCA authorization or stop lending (Freshfields, 2026).
For a product that grew for a decade with no consumer-credit license requirement, this is the first time a UK regulator can examine a BNPL lender's affordability checks the way it already examines a credit card issuer's.
FIS bets embedded finance works better with the bank still in the loop
In the United States, FIS launched its Embedded Banking Platform on September 3, 2026, the company's first embedded finance product built specifically for banks rather than around them (FIS, 2026). The platform lets banks offer account opening, card issuing, accounts receivable, accounts payable and expense management directly inside the accounting and business software their corporate customers already use. Pilot banks Cogent Bank, Commercial Bank of California and M&T Bank are testing it ahead of a planned fourth-quarter 2026 launch of accounts and payments (FIS, 2026; fintech.global, 2026).
The design choice that separates it from earlier embedded finance models: deposits and accounts stay on the bank's own ledger and balance sheet, rather than moving to a program manager or fintech intermediary's books. That keeps the bank, not a technology partner, as the entity with the direct regulatory relationship to the end customer.
That distinction has mattered more since July 2024, when the Federal Reserve, FDIC and OCC jointly flagged safety, compliance and consumer-protection concerns in how banks manage third-party arrangements to deliver deposit products, and opened a formal request for information on bank-fintech partnerships (OCC, 2024; FDIC, 2024). FIS is not the arrangement regulators were describing in that statement, but the new platform is a direct response to the environment it created: embedded finance a bank's own compliance team can still fully see and control.
What to watch next
Britain's clock runs first. DPC firms that entered the temporary permissions regime have until mid-January 2027, six months after Regulation Day, to win full FCA authorization or stop lending (Freshfields, 2026). FIS has said account opening and payments on its new platform are targeted for the fourth quarter of 2026, which will be the first real test of whether banks can compete with fintech-style account experiences without moving the ledger off their own books. And in India, any NBFC eligible for the new unregistered category needs to get the actual filing deadline from RBI directly rather than relying on the conflicting dates now circulating in legal commentary.
Sources
- Mondaq. "RBI Notifies Draft RBI (NBFC – Registration, Exemptions and Framework for Scale Based Regulation) Amendment Directions, 2026." 2026. https://www.mondaq.com/india/financial-services/1751636/rbi-notifies-draft-rbi-nbfc-registration-exemptions-and-framework-for-scale-based-regulation-amendment-directions-2026
- Lexology. "RBI Notifies Regulations on Exempted NBFCs." 2026. https://www.lexology.com/library/detail.aspx?g=6753daa1-87b3-43d0-afe5-b9982fc57f83
- Corporate Professionals. "FAQs on 'Unregistered Type I NBFCs'." 2026. https://www.corporateprofessionals.com/articles/faqs-on-unregistered-type-i-nbfcs-registration-exemption-deregistration-framework-under-the-rbi-nbfc-registration-exemptions-and-framework-for-scale-based-regulation-amendment-di/
- CorpLawUpdates.in. "RBI Creates 'Type I NBFC' Category and Opens Deregistration Window: NBFC Registration Amendment Directions, 2026." 2026. https://www.corplawupdates.in/updates/rbi-nbfc-type-i-registration-amendment-directions-2026-deregistration
- Financial Conduct Authority. "PS26/1: Regulation of Deferred Payment Credit (unregulated Buy Now Pay Later)." February 11, 2026. https://www.fca.org.uk/publications/policy-statements/ps26-1-regulation-deferred-payment-credit
- Financial Conduct Authority. "New protections confirmed for Buy Now Pay Later borrowers." 2026. https://www.fca.org.uk/news/press-releases/new-protections-confirmed-buy-now-pay-later-borrowers
- Freshfields. "UK BNPL Regime: FCA publishes final rules." 2026. https://www.freshfields.com/en/our-thinking/blogs/risk-and-compliance/uk-bnpl-regime-fca-publishes-final-rules-102mkqc
- FIS. "FIS Launches Embedded Banking Platform, Letting Banks Deliver Accounts and Payments Inside Business Software." September 3, 2026. https://www.fisglobal.com/about-us/media-room/press-release/2026/fis-launches-embedded-banking-platform
- fintech.global. "FIS launches embedded banking platform for US banks." September 4, 2026. https://fintech.global/2026/09/04/fis-launches-embedded-banking-platform-for-us-banks/
- American Banker. "M&T taps embedded banking to improve ties to corporate clients." 2026. https://www.americanbanker.com/payments/news/m-t-taps-embedded-banking-to-improve-ties-to-corporate-clients
- Office of the Comptroller of the Currency. "Agencies Remind Banks of Potential Risks Associated with Third-Party Deposit Arrangements and Request Additional Information on Bank-Fintech Arrangements." July 2024. https://www.occ.treas.gov/news-issuances/news-releases/2024/nr-ia-2024-85.html
- FDIC. "Agencies Issue Statement on Bank Arrangements with Third Parties to Deliver Deposit Products and Issue Request for Information Seeking Input on Bank-Fintech Arrangements." July 2024. https://www.fdic.gov/news/financial-institution-letters/2024/agencies-issue-statement-bank-arrangements-third-parties