Challenges and policy implications of Buy-Now-Pay Later in the UK: A multidisciplinary framework to map digital vulnerabilities

This paper is concerned with the current and emerging digital vulnerabilities in unsecured consumer credit markets, and particularly focuses on Buy-Now-Pay-Later (BNPL) platforms in the UK. The exponential growth of the BNPL sector across the UK and beyond has extended digital vulnerabilities in what remains thus far a largely unregulated space. The risks and algorithmic applications associated with the BNPL process are obfuscated, and the interactions of people and processes with the digital are giving rise to new and emerging vulnerabilities that are intersecting and nuanced. Consumers using BNPL platforms often do not realise how their data is used while the credit products are offered for free, effectively obfuscating the price that is being paid. This paper reviews current debates in management, law, AI and machine learning, design and Human Computer Interaction (HCI), and Corporate Social Responsibility (CSR) and sustainability in order to reframe current understandings of digital vulnerability. We propose a multidisciplinary framework highlighting how digital vulnerabilities emerge and intersect within Financial, Algorithmic, Regulatory, and Ethical (FARE) domains. The framework provides a roadmap for policy makers to identify and address digital vulnerabilities in digital platforms. The paper invites further research on how digital vulnerabilities emerge and can be mitigated in digital platforms.