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Malaysia's BNPL providers face 30 November licensing cut-off and RM2 million equity floor

Published Data as of Research noteMalaysiaRegulationBNPLCredit bureau
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Key points

Implications for lenders

Non-bank lenders and BNPL providers in Malaysia need their SKP application in by 30 November to keep operating, and BNPL licensees must hold at least RM2 million. Underwriting can use bureau scores but must add affordability checks above RM1,000 and bankruptcy screening, and collections teams may need new controls to keep within three times a week.

Implications

ExecutivesNon-bank lenders and BNPL providers in Malaysia need an application filed by 30 November and a plan to start bureau reporting within a year of authorisation.
InvestorsThe equity floor and reporting duties raise fixed costs, which may favour larger BNPL players and those with bank or e-commerce parents.
OperatorsBuild affordability checks, bankruptcy screening, monthly bureau files and contact-frequency limits into the loan workflow before authorisation.

Facts

Licensing window: the Consumer Credit Act 2025 came into force on 1 March 2026 and its licensing and registration part on 1 June 2026. According to SKP's FAQs on its authorisation and conduct standards (updated 24 September 2026), existing industry participants have from 1 June to 30 November 2026 to apply for authorisation and may keep operating while SKP decides, provided they applied within the window. New entrants may not start regulated activities until authorised. Debt collection agencies must also apply by 30 November. SKP reviews an application in about three months once it is complete. 1

Financial thresholds: a BNPL licence is issued only once the provider holds shareholders' funds or total equity of at least RM2 million, with no conditional licence for a shortfall. 2 Debt collection agencies need RM500,000, or a lower amount combined with professional indemnity insurance. 3

Underwriting and reporting: BNPL providers must assess affordability for individual consumers above RM1,000. 4 Creditworthiness checks must include bankruptcy screening, self-declaration alone is not enough, and bureau scores may be used but not in isolation. Micro and small enterprises count as credit consumers for credit up to RM300,000. 5 Non-bank credit providers must submit positive and negative data monthly to at least one credit reporting agency, starting within 12 months of authorisation. 6

Pricing and collection: flat-rate and Rule of 78 methods are prohibited for BNPL, late charges may not include funding or third-party recovery costs, merchants may not make BNPL the default payment option, and BNPL may not be used for cash withdrawals. Collection may begin only seven days after the required reminders and notices 7 and is limited to 8 a.m. to 9 p.m., 8 up to three times a week 9 or 12 times a month unless otherwise agreed. 10

Bank-side rules: Bank Negara Malaysia's Policy Document on Personal Financing (30 September 2025) bans flat-rate and Rule of 78 pricing for personal financing and requires applicants for financing above RM100,000 to complete a financial education module, both from 1 January 2027. 11

Market size: the Ministry of Finance told Parliament in July that Malaysia had 8 million active BNPL account holders in the first quarter of 2026 12 with RM5.3 billion outstanding, 13 of which 3.4% was overdue. 14 BNPL was about about 0.3% of household debt at end-2025. 15

Analysis

Convergence of bank and non-bank rules: from 1 January 2027, BNPL providers and banks will both be barred from flat-rate and Rule of 78 pricing, and non-bank providers must start reporting to credit bureaus within a year of authorisation. BNPL is small relative to household debt, but its overdue share of 3.4% compares with 0.96% of bank household loans three or more months in arrears at end-June. 16 The measures differ (any overdue amount versus three months or more), so the gap overstates the difference in loss risk, but it shows why the regulator is pairing affordability checks with bureau reporting.

Cross-country: neighbouring markets are tightening collection rules at the same time. The Philippine SEC's draft rules would require third-party collectors to be accredited, with one year for existing agencies to comply after the rules take effect. 17 In Indonesia, online-lending arrears of more than ninety days reached 4.73% in August, 18 a reminder of what weak underwriting in short-tenor digital credit can produce. Malaysia's approach sets the conduct limits in the licensing standards from the start.

Counterpoints and uncertainties

The FAQs are guidance and may be updated again before the deadline; SKP has not published how many applications it has received, so the share of providers that will be authorised is unknown. A review time measured in months means many firms will operate on pending applications into 2027, and the conduct standards' practical enforcement is still untested. The BNPL market figures date from the first quarter and may have changed since.

Key figures

  1. SKP review time for a complete application: about three months. Indicative SKP review period, counted from when an application is deemed complete. Malaysia, credit providers regulated under the Consumer Credit Act 2025. Basis date: 24 Sep 2026. Source: Suruhanjaya Kredit Pengguna (SKP): FAQs on Authorisation Standards, CORE System and Conduct Standards, v1.1 (2026-09-24)
  2. Minimum shareholders' funds for a BNPL licence (SKP): RM2 million. Minimum shareholders' funds or total equity before SKP issues a BNPL licence. Malaysia, credit providers regulated under the Consumer Credit Act 2025. Basis date: 24 Sep 2026. Source: Suruhanjaya Kredit Pengguna (SKP): FAQs on Authorisation Standards, CORE System and Conduct Standards, v1.1 (2026-09-24)
  3. Minimum shareholders' funds for a debt collection agency (SKP): RM500,000. Minimum shareholders' funds or total equity for debt collection agencies (lower option with indemnity insurance available). Malaysia, credit providers regulated under the Consumer Credit Act 2025. Basis date: 24 Sep 2026. Source: Suruhanjaya Kredit Pengguna (SKP): FAQs on Authorisation Standards, CORE System and Conduct Standards, v1.1 (2026-09-24)
  4. BNPL affordability-assessment threshold (SKP): RM1,000. BNPL credit above which providers must assess an individual consumer's affordability. Malaysia, credit providers regulated under the Consumer Credit Act 2025. Basis date: 24 Sep 2026. Source: Suruhanjaya Kredit Pengguna (SKP): FAQs on Authorisation Standards, CORE System and Conduct Standards, v1.1 (2026-09-24)
  5. Credit ceiling for micro and small enterprises treated as credit consumers (SKP): RM300,000. Principal amount up to which credit to micro and small enterprises falls under consumer protection. Malaysia, credit providers regulated under the Consumer Credit Act 2025. Basis date: 24 Sep 2026. Source: Suruhanjaya Kredit Pengguna (SKP): FAQs on Authorisation Standards, CORE System and Conduct Standards, v1.1 (2026-09-24)
  6. Deadline for non-bank credit providers to start credit reporting (SKP): 12 months. Time after authorisation within which non-bank credit providers must report to a credit reporting agency. Malaysia, credit providers regulated under the Consumer Credit Act 2025. Basis date: 24 Sep 2026. Source: Suruhanjaya Kredit Pengguna (SKP): FAQs on Authorisation Standards, CORE System and Conduct Standards, v1.1 (2026-09-24)
  7. Minimum wait before collection starts (SKP): seven days. Minimum days after required reminders and notices before collection may start. Malaysia, credit providers regulated under the Consumer Credit Act 2025. Basis date: 24 Sep 2026. Source: Suruhanjaya Kredit Pengguna (SKP): FAQs on Authorisation Standards, CORE System and Conduct Standards, v1.1 (2026-09-24)
  8. Permitted debt-collection contact hours (SKP): 8 a.m. to 9 p.m.. Hours during which collectors may contact a consumer. Malaysia, credit providers regulated under the Consumer Credit Act 2025. Basis date: 24 Sep 2026. Source: Suruhanjaya Kredit Pengguna (SKP): FAQs on Authorisation Standards, CORE System and Conduct Standards, v1.1 (2026-09-24)
  9. Maximum debt-collection contacts per week (SKP): three times a week. Maximum collection contacts with a consumer per week unless otherwise agreed. Malaysia, credit providers regulated under the Consumer Credit Act 2025. Basis date: 24 Sep 2026. Source: Suruhanjaya Kredit Pengguna (SKP): FAQs on Authorisation Standards, CORE System and Conduct Standards, v1.1 (2026-09-24)
  10. Maximum debt-collection contacts per month (SKP): 12 times a month. Maximum collection contacts with a consumer per month unless otherwise agreed. Malaysia, credit providers regulated under the Consumer Credit Act 2025. Basis date: 24 Sep 2026. Source: Suruhanjaya Kredit Pengguna (SKP): FAQs on Authorisation Standards, CORE System and Conduct Standards, v1.1 (2026-09-24)
  11. Personal financing amount requiring a financial education module (BNM): RM100,000. Personal financing above which applicants must complete a financial education module, from 1 January 2027. Malaysia, personal financing by BNM-regulated institutions. Basis date: 30 Sep 2025. Source: Bank Negara Malaysia: Policy Document on Personal Financing (2025-09-30)
  12. Active BNPL account holders: 8 million. Active BNPL account holders, Ministry of Finance written parliamentary reply. Malaysia, BNPL. Basis date: 31 Mar 2026. Source: Malay Mail: Finance Ministry — BNPL users hit eight million as outstanding balances reach RM5.3b (2026-07-16)
  13. BNPL outstanding balance: RM5.3 billion. Total outstanding BNPL balances, Ministry of Finance. Malaysia, BNPL. Basis date: 31 Mar 2026. Source: Malay Mail: Finance Ministry — BNPL users hit eight million as outstanding balances reach RM5.3b (2026-07-16)
  14. BNPL overdue share of outstanding: 3.4%. Overdue BNPL amounts as a share of outstanding balances, Ministry of Finance. Malaysia, BNPL. Basis date: 31 Mar 2026. Source: Malay Mail: Finance Ministry — BNPL users hit eight million as outstanding balances reach RM5.3b (2026-07-16)
  15. BNPL share of household debt: about 0.3%. BNPL debt as a share of total household debt, Ministry of Finance. Malaysia, households. Basis date: 31 Dec 2025. Source: Malay Mail: Finance Ministry — BNPL users hit eight million as outstanding balances reach RM5.3b (2026-07-16)
  16. Household loans three or more months in arrears (MIA-3, BNM): 0.96% (up from 0.92% at end-March 2026 and 0.89% at end-June 2025). Household loans three or more months in arrears, % of outstanding household loans by value (BNM). Malaysia, banking system household loans. Basis date: 30 Jun 2026. Source: BNM Insights: Beyond Oil Prices — From Geopolitical Conflict to Financial Stability Risk (October 2026)
  17. Proposed transition period for existing collection agencies (SEC draft): one year. Time existing third-party collection agencies would have after the rules take effect to obtain accreditation. Philippines, third-party collection agencies. Basis date: 5 Oct 2026. Source: Fintech News Philippines: SEC Proposes Accreditation for Third-Party Debt Collection Agencies (2026-10-05)
  18. Online lending TWP90 (90+ day arrears): 4.73% (up from 4.32% in July). Share of outstanding loans more than ninety days past due, industry-wide (OJK TWP90). Licensed online lending (pindar / P2P) platforms. Basis date: 31 Aug 2026. Source: OJK: Siaran Pers RDKB September 2026 (SP 185/OJK/DKPU/X/2026, 2026-10-05)

Sources

  1. Suruhanjaya Kredit Pengguna (SKP): FAQs on Authorisation Standards, CORE System and Conduct Standards, v1.1 (2026-09-24)primary
  2. SKP: Enforcement of the Consumer Credit Act 2025 and the establishment of the Consumer Credit Commissionprimary
  3. Bank Negara Malaysia: Policy Document on Personal Financing (2025-09-30)primary
  4. Malay Mail: Finance Ministry — BNPL users hit eight million as outstanding balances reach RM5.3b (2026-07-16)
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A Japanese version of this article is available: 日本語版

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