CFPB Report: BNPL Market Growth and Collection Strategies for 2026
The Consumer Financial Protection Bureau (CFPB) released a new Data Spotlight this month, providing a deep dive into the evolving “Buy Now, Pay Later” (BNPL) market. The report, which analyzes data from six major industry players including Affirm, Cash App Afterpay, Klarna, PayPal, Sezzle, and Zip, shows a market that is maturing but still expanding its reach across the American consumer base.
Market Expansion by the Numbers
While the explosive “hyper-growth” phase seen in early 2021 has leveled off, the BNPL sector continues to see significant gains. Between 2022 and 2023, the number of BNPL loans originated by the surveyed lenders grew by 23%, reaching 335.8 million loans. In terms of dollar volume, originations rose to $45.2 billion in 2023, a 26% increase when adjusted for inflation.
Perhaps most notably for the accounts receivable management (ARM) industry, the intensity of use is rising. The report found:
- Higher Frequency: Borrowers took an average of 6.3 BNPL loans per lender in 2023, up 11% from 2022.
- Larger Balances: The average annual dollar amount per user increased by 14%, rising to $848 (inflation-adjusted).
- Unique User Growth: Approximately 53.6 million consumers took out at least one BNPL loan in 2023, a 12% year-over-year increase.
The Collection Agency Perspective: Insights from Mellisa Massey
As BNPL becomes a staple of the retail experience, the debt collection and debt sale landscape must adapt. Mellisa Massey, Director of Business Development at NCA, notes that the unique structure of BNPL debt requires a specialized approach.
“The CFPB report highlights a critical trend: consumers aren’t just using BNPL once; they are integrating it into their monthly financial habits,” says Massey. “For debt collectors, this means we are seeing a higher volume of smaller-balance accounts. Success in this space isn’t about traditional ‘heavy-handed’ collections; it’s about high-frequency, low-friction digital engagement that mirrors the original BNPL user experience.”
Massey also pointed to the report’s findings on “loan stacking,” where users may have simultaneous loans across multiple lenders that don’t appear on traditional credit reports.
“The lack of centralized reporting for these ‘pay-in-four’ products creates an invisible risk layer,” Massey explains. “Agencies and debt buyers need to be more sophisticated in how they assess a consumer’s total debt burden. When a consumer defaults on a $135 BNPL loan, it’s often a canary in the coal mine for broader financial distress.”
Declining Charge-Offs and Late Fees
Interestingly, the CFPB report noted a decline in delinquency metrics. In 2023, the loan charge-off rate dropped to 1.83%, down from 2.63% in 2022. Late fee revenue also decreased as a share of total volume, with only 4.1% of loans being assessed a late fee in 2023 compared to 5.2% the year prior.
The CFPB attributes this trend to lenders tightening their underwriting standards and diversifying their product offerings.
Looking Ahead
As the BNPL market continues to expand its footprint, the ARM industry must remain agile. The CFPB’s report makes it clear: BNPL is no longer a niche product, it is a permanent fixture of the consumer credit ecosystem.
