How to read this tracker
Each state row records three sourced facts: whether a dedicated buy-now-pay-later statute exists, who the state's consumer-credit regulator is, and the most recent observed activity (a statute, regulator guidance or enforcement, an attorney general action, or an introduced bill) with its date and link. Rows are tiered: Tier 1, dedicated statute; Tier 2, regulator has taken a public position or enforcement action; Tier 3, attorney general action or a bill introduced but not enacted; Tier 4, no observed activity.
For Tier 4 rows, "No observed activity as of September 9, 2026" means no qualifying activity was found in the three specified official source categories checked for that state: the consumer-credit regulator site, attorney general press releases since January 1, 2025, and the legislature bill search for the current and prior session. It is not a broader legal conclusion. Most states have general lending, installment, or licensing laws that may or may not reach a given product; this tracker does not say whether any product or provider is covered by them. That is a question for counsel.
Summary by tier
- Tier 1, dedicated statute (2): Illinois, New York
- Tier 2, regulator position or enforcement (3): California, Ohio, Oregon
- Tier 3, attorney general or legislative activity (6): Colorado, Connecticut, Massachusetts, Minnesota, North Carolina, Wisconsin
- Tier 4, no observed activity (39): Alabama, Alaska, Arizona, Arkansas, Delaware, Florida, Georgia, Hawaii, Idaho, Indiana, Iowa, Kansas, Kentucky, Louisiana, Maine, Maryland, Michigan, Mississippi, Missouri, Montana, Nebraska, Nevada, New Hampshire, New Jersey, New Mexico, North Dakota, Oklahoma, Pennsylvania, Rhode Island, South Carolina, South Dakota, Tennessee, Texas, Utah, Vermont, Virginia, Washington, West Virginia, Wyoming
Federal backdrop
The CFPB's 2024 interpretive rule treating pay-in-four BNPL as credit cards for Regulation Z purposes was withdrawn on May 12, 2025, and the Bureau has not issued a replacement. On December 1, 2025, the attorneys general of California, Colorado, Connecticut, Illinois, Minnesota, North Carolina, and Wisconsin sent letters to six BNPL providers seeking information on ability-to-repay practices, fees, disputes, and credit reporting; the inquiry sought information and is not a finding. State law and state enforcement are where buy-now-pay-later rulemaking is currently happening.
All fifty states
State by state
Alabama
Dedicated BNPL statute: None as of September 9, 2026
Consumer-credit regulator: Alabama State Banking Department
Most recent observed activity: No observed activity as of September 9, 2026
Tier: 4. Last checked: Sep 9, 2026.
Sources checked
Alaska
Dedicated BNPL statute: None as of September 9, 2026
Consumer-credit regulator: Alaska Division of Banking and Securities
Most recent observed activity: No observed activity as of September 9, 2026
Tier: 4. Last checked: Sep 9, 2026.
Sources checked
Arkansas
Dedicated BNPL statute: None as of September 9, 2026
Consumer-credit regulator: Arkansas Securities Department
Most recent observed activity: No observed activity as of September 9, 2026
Tier: 4. Last checked: Sep 9, 2026.
Sources checked
California
Dedicated BNPL statute: None as of September 9, 2026
Consumer-credit regulator: California Department of Financial Protection and Innovation
Most recent observed activity: On December 1, 2025, the California Attorney General announced a seven-state inquiry that sent letters to six BNPL providers concerning ability-to-repay practices, fees, disputes, and credit reporting; the inquiry sought information and is not a finding. Separately, DFPI's August 9, 2022 settlement with Four Technologies required the company to cease unlicensed lending, obtain a California Financing Law license before making future California loans, and refund fees.
Tier: 2. Last checked: Sep 14, 2026.
Sources checked
Delaware
Dedicated BNPL statute: None as of September 9, 2026
Consumer-credit regulator: Delaware Office of the State Bank Commissioner
Most recent observed activity: No observed activity as of September 9, 2026
Tier: 4. Last checked: Sep 9, 2026.
Sources checked
Florida
Dedicated BNPL statute: None as of September 9, 2026
Consumer-credit regulator: Florida Office of Financial Regulation
Most recent observed activity: No observed activity as of September 9, 2026
Tier: 4. Last checked: Sep 9, 2026.
Sources checked
Georgia
Dedicated BNPL statute: None as of September 9, 2026
Consumer-credit regulator: Georgia Department of Banking and Finance
Most recent observed activity: No observed activity as of September 9, 2026
Tier: 4. Last checked: Sep 9, 2026.
Sources checked
Hawaii
Dedicated BNPL statute: None as of September 9, 2026
Consumer-credit regulator: Hawaii Division of Financial Institutions
Most recent observed activity: No observed activity as of September 9, 2026
Tier: 4. Last checked: Sep 9, 2026.
Sources checked
Indiana
Dedicated BNPL statute: None as of September 9, 2026
Consumer-credit regulator: Indiana Department of Financial Institutions
Most recent observed activity: No observed activity as of September 9, 2026
Tier: 4. Last checked: Sep 9, 2026.
Sources checked
Iowa
Dedicated BNPL statute: None as of September 9, 2026
Consumer-credit regulator: Iowa Division of Banking
Most recent observed activity: No observed activity as of September 9, 2026
Tier: 4. Last checked: Sep 9, 2026.
Sources checked
Kentucky
Dedicated BNPL statute: None as of September 9, 2026
Consumer-credit regulator: Kentucky Department of Financial Institutions
Most recent observed activity: No observed activity as of September 9, 2026
Tier: 4. Last checked: Sep 9, 2026.
Sources checked
Louisiana
Dedicated BNPL statute: None as of September 9, 2026
Consumer-credit regulator: Louisiana Office of Financial Institutions
Most recent observed activity: No observed activity as of September 9, 2026
Tier: 4. Last checked: Sep 9, 2026.
Sources checked
Maine
Dedicated BNPL statute: None as of September 9, 2026
Consumer-credit regulator: Maine Bureau of Consumer Credit Protection
Most recent observed activity: No observed activity as of September 9, 2026
Tier: 4. Last checked: Sep 9, 2026.
Sources checked
Maryland
Dedicated BNPL statute: None as of September 9, 2026
Consumer-credit regulator: Maryland Office of Financial Regulation
Most recent observed activity: No observed activity as of September 9, 2026
Tier: 4. Last checked: Sep 9, 2026.
Sources checked
Massachusetts
Dedicated BNPL statute: None as of September 9, 2026
Consumer-credit regulator: Massachusetts Division of Banks
Most recent observed activity: Massachusetts Senate Bill S.692 (193rd General Court), An Act protecting consumers engaging with buy now pay later lenders, was filed January 19, 2023 and accompanied study order S.2792 on May 20, 2024. It is prior-session legislative activity, not an enacted dedicated BNPL statute. Whether successor legislation was filed in the 194th General Court had not been confirmed as of September 14, 2026.
Tier: 3. Last checked: Sep 14, 2026.
Also noted: Section 303 of Acts of 2024, Chapter 238 established a broader payments study commission whose scope includes BNPL, with a December 1, 2025 report deadline. Report delivery not verified. This does not create a dedicated BNPL regulatory regime. Source.
Sources checked
Mississippi
Dedicated BNPL statute: None as of September 9, 2026
Consumer-credit regulator: Mississippi Department of Banking and Consumer Finance
Most recent observed activity: No observed activity as of September 9, 2026
Tier: 4. Last checked: Sep 9, 2026.
Sources checked
Missouri
Dedicated BNPL statute: None as of September 9, 2026
Consumer-credit regulator: Missouri Division of Finance
Most recent observed activity: No observed activity as of September 9, 2026
Tier: 4. Last checked: Sep 9, 2026.
Sources checked
Montana
Dedicated BNPL statute: None as of September 9, 2026
Consumer-credit regulator: Montana Division of Banking and Financial Institutions
Most recent observed activity: No observed activity as of September 9, 2026
Tier: 4. Last checked: Sep 9, 2026.
Sources checked
Nebraska
Dedicated BNPL statute: None as of September 9, 2026
Consumer-credit regulator: Nebraska Department of Banking and Finance
Most recent observed activity: No observed activity as of September 9, 2026
Tier: 4. Last checked: Sep 9, 2026.
Sources checked
Nevada
Dedicated BNPL statute: None as of September 9, 2026
Consumer-credit regulator: Nevada Financial Institutions Division
Most recent observed activity: No observed activity as of September 9, 2026
Tier: 4. Last checked: Sep 9, 2026.
Sources checked
New Hampshire
Dedicated BNPL statute: None as of September 9, 2026
Consumer-credit regulator: New Hampshire Banking Department
Most recent observed activity: No observed activity as of September 9, 2026
Tier: 4. Last checked: Sep 9, 2026.
Sources checked
New Jersey
Dedicated BNPL statute: None as of September 9, 2026
Consumer-credit regulator: New Jersey Department of Banking and Insurance
Most recent observed activity: No observed activity as of September 9, 2026
Tier: 4. Last checked: Sep 9, 2026.
Sources checked
New Mexico
Dedicated BNPL statute: None as of September 9, 2026
Consumer-credit regulator: New Mexico Financial Institutions Division
Most recent observed activity: No observed activity as of September 9, 2026
Tier: 4. Last checked: Sep 9, 2026.
Sources checked
New York
Dedicated BNPL statute: Yes. New York Banking Law Article 14-B, enacted May 9, 2025. Source.
Consumer-credit regulator: New York State Department of Financial Services
Most recent observed activity: New 3 NYCRR Part 423 and amendments to 23 NYCRR Part 101 were formally proposed and published July 15, 2026. The public comment period closed September 14, 2026. As of September 15, 2026, DFS continues to list the regulations as proposed and does not list a Notice of Adoption; the regulations take effect 180 days after a Notice of Adoption is published.
Tier: 1. Last checked: Sep 15, 2026.
Note: This row is checked weekly.
Sources checked
- New York State Department of Financial Services: https://www.dfs.ny.gov/industry_guidance/regulatory_activity/banking (checked Sep 15, 2026)
- New York attorney general press releases: https://ag.ny.gov/press-releases (checked Sep 9, 2026)
- New York legislature bill search: https://www.nysenate.gov/legislation (checked Sep 9, 2026) Source offered no keyword search to automation on Oct 1, 2026; last verified Sep 9, 2026.
- New York State Register, July 15, 2026: https://dos.ny.gov/july-15-2026vol-xlviii-issue-28 (checked Sep 9, 2026)
- DFS proposed 3 NYCRR Part 423, text: https://www.dfs.ny.gov/industry-guidance/regulations/proposed/banking/rp-bank-3nycrr-423-text (checked Sep 14, 2026)
North Dakota
Dedicated BNPL statute: None as of September 9, 2026
Consumer-credit regulator: North Dakota Department of Financial Institutions
Most recent observed activity: No observed activity as of September 9, 2026
Tier: 4. Last checked: Sep 9, 2026.
Sources checked
Ohio
Dedicated BNPL statute: None as of September 9, 2026
Consumer-credit regulator: Ohio Department of Commerce, Division of Financial Institutions
Most recent observed activity: Ohio Division of Financial Institutions Bank Partnership Guidance is current as of October 31, 2025 and states that the Division suspended its prior position requiring certain nonbank arrangers of bank loans to obtain a Small Loan Act license unless or until further notice. Senate Bill 269 remained a legislative dependency during this check.
Tier: 2. Last checked: Sep 9, 2026.
Note: This row is checked weekly.
Sources checked
- Ohio Department of Commerce, Division of Financial Institutions: https://com.ohio.gov/divisions-and-programs/financial-institutions (checked Sep 9, 2026)
- Ohio attorney general press releases: https://www.ohioattorneygeneral.gov/Media/News-Releases (checked Sep 9, 2026)
- Ohio legislature bill search: https://www.legislature.ohio.gov/legislation (checked Sep 9, 2026) Source blocked to automated access on Oct 1, 2026; last verified Sep 9, 2026.
- Ohio Senate Bill 269, 136th General Assembly: https://ohiosenate.gov/legislation/136/sb269 (checked Sep 9, 2026)
- Ohio Bank Partnership Guidance, Wayback Machine snapshot: https://web.archive.org/web/20261001211719/https://com.ohio.gov/divisions-and-programs/financial-institutions/consumer-finance/guides-and-resources/bank_partnership_guidance (checked Oct 1, 2026)
Oklahoma
Dedicated BNPL statute: None as of September 9, 2026
Consumer-credit regulator: Oklahoma Department of Consumer Credit
Most recent observed activity: No observed activity as of September 9, 2026
Tier: 4. Last checked: Sep 9, 2026.
Sources checked
Pennsylvania
Dedicated BNPL statute: None as of September 9, 2026
Consumer-credit regulator: Pennsylvania Department of Banking and Securities
Most recent observed activity: No observed activity as of September 9, 2026
Tier: 4. Last checked: Sep 9, 2026.
Sources checked
South Dakota
Dedicated BNPL statute: None as of September 9, 2026
Consumer-credit regulator: South Dakota Division of Banking
Most recent observed activity: No observed activity as of September 9, 2026
Tier: 4. Last checked: Sep 9, 2026.
Sources checked
Tennessee
Dedicated BNPL statute: None as of September 9, 2026
Consumer-credit regulator: Tennessee Department of Financial Institutions
Most recent observed activity: No observed activity as of September 9, 2026
Tier: 4. Last checked: Sep 9, 2026.
Sources checked
Texas
Dedicated BNPL statute: None as of September 9, 2026
Consumer-credit regulator: Texas Office of Consumer Credit Commissioner
Most recent observed activity: No observed activity as of September 9, 2026
Tier: 4. Last checked: Sep 9, 2026.
Sources checked
Utah
Dedicated BNPL statute: None as of September 9, 2026
Consumer-credit regulator: Utah Department of Financial Institutions
Most recent observed activity: No observed activity as of September 9, 2026
Tier: 4. Last checked: Sep 9, 2026.
Sources checked
Vermont
Dedicated BNPL statute: None as of September 9, 2026
Consumer-credit regulator: Vermont Department of Financial Regulation
Most recent observed activity: No observed activity as of September 9, 2026
Tier: 4. Last checked: Sep 9, 2026.
Sources checked
Washington
Dedicated BNPL statute: None as of September 9, 2026
Consumer-credit regulator: Washington State Department of Financial Institutions
Most recent observed activity: No observed activity as of September 9, 2026
Tier: 4. Last checked: Sep 9, 2026.
Also noted: The House Consumer Protection and Business Committee held a January 13, 2026 work session titled Overview of Buy Now Pay Later Transactions. Under the requested tier rule, a work session without an introduced BNPL bill did not change the row from Tier 4. Source.
Sources checked
West Virginia
Dedicated BNPL statute: None as of September 9, 2026
Consumer-credit regulator: West Virginia Division of Financial Institutions
Most recent observed activity: No observed activity as of September 9, 2026
Tier: 4. Last checked: Sep 9, 2026.
Sources checked
Wyoming
Dedicated BNPL statute: None as of September 9, 2026
Consumer-credit regulator: Wyoming Division of Banking
Most recent observed activity: No observed activity as of September 9, 2026
Tier: 4. Last checked: Sep 9, 2026.
Sources checked
Frequently asked questions
- Which states have buy-now-pay-later laws?
- As of October 1, 2026, New York and Illinois have enacted dedicated buy-now-pay-later statutes. New York's Banking Law Article 14-B takes effect 180 days after DFS adopts its final rule, which had not happened on the check date; Illinois's Public Act 104-475 requires compliance from January 1, 2028.
- Does my state regulate buy now pay later?
- Most states have no dedicated buy-now-pay-later statute. This tracker records, for each state, whether a dedicated statute exists, who the consumer-credit regulator is, and the most recent observed regulator, attorney general, or legislative activity, each with a date and a link. It does not say whether any product is covered by a state's general lending laws; that is a question for counsel.
- When does New York's BNPL law take effect?
- New York's Buy-Now-Pay-Later Act was signed May 9, 2025, but takes effect 180 days after DFS publishes a Notice of Adoption of its final rule. DFS published the formal proposed rule on July 15, 2026 and the comment period closed September 14, 2026, so no effective date has been set.
- What does "no observed activity" mean on this tracker?
- It means that on the check date, no buy-now-pay-later statute, regulator guidance, enforcement action, attorney general action, or introduced bill was found in three sources for that state: the consumer-credit regulator's site, the attorney general's press releases since January 1, 2025, and the legislature's bill search for the current and prior session. It is not a broader legal conclusion.
Sources
Every row carries its own sources above. Primary sources used across the page:
- New York Department of Financial Services, regulatory activity (banking), Part 423 proposal and 23 NYCRR Part 101 amendments published July 15, 2026; comment period closed September 14, 2026. dfs.ny.gov
- New York Banking Law Article 14-B. nysenate.gov
- Illinois General Assembly, SB3561, Public Act 104-475. ilga.gov
- California Attorney General, press release, December 1, 2025. oag.ca.gov
- Ohio Department of Commerce, Division of Financial Institutions, Bank Partnership Guidance, current as of October 31, 2025. com.ohio.gov
- Oregon Division of Financial Regulation, proposed bulletin DFR 2026-X. dfr.oregon.gov
- Consumer Financial Protection Bureau, buy-now-pay-later compliance resources (withdrawal of the 2024 interpretive rule, May 12, 2025). consumerfinance.gov
- Congressional Research Service, R48858, Buy Now, Pay Later: Policy Issues and Options for Congress. congress.gov
This page is general information, not legal advice. Arclo is not a lender and does not make credit decisions. Statute and rule text govern; links go to primary documents where available. To report an error or a change in any state, contact Arclo through the site.
