The Decoupling Effect - Payment Timing and Deferred Payment Credit

Point-of-sale instalment credit reached a market of over GBP 13 billion a year in the United Kingdom, and 10.9 million adult users, without ever presenting itself to those users as borrowing. On 15 July 2026 it entered the Financial Conduct Authority's consumer credit perimeter as deferred payment credit, and the argument that had run for five years about whether the product harms the people who use it was carried across the boundary intact. Providers point to repayment records in which ninety-five per cent of instalments arrive early or on time and losses run below half a per cent. The advice sector points to casework that has more than quadrupled since 2022, to users who borrow to repay, and to enforcement agents at the door. This paper argues that both readings are answers to a question about price, and that the product's behavioural signature is not a price at all. What deferred payment credit changes is the moment at which cost is felt: it separates the experience of acquiring from the experience of paying, divides a single affordability judgement into four that are never re-evaluated together, and distributes exposure across providers none of whom observes the total. Read that way, the regime that arrived in July 2026 is addressed to what the consumer is told, at the moment of application, by one lender at a time. The mechanism runs on when the consumer pays, at the moment of impulse, across lenders. The paper sets out the mechanism from the experimental literature, identifies three layers at which informational remedies cannot reach it, specifies the behavioural endpoints on which the regime should be judged rather than the disclosure obligations on which it is currently defended, and proposes reforms that bind design rather than wording.