Buy Now, Pay Later (BNPL) has become the preferred payment method for an entire generation: approximately 30% of German online shoppers regularly use installment payments or invoice purchases (Statista). However, from November 20, 2026, the revised EU Consumer Credit Directive (CCD II) will impose strict regulatory requirements — similar to the Green Claims Directive — on these payment forms for the first time. For e-commerce retailers, this means: anyone offering BNPL options at checkout must meet new compliance requirements - from credit checks to expanded disclosure duties.
What Is the EU Consumer Credit Directive (CCD II)?
Directive (EU) 2023/2225 - also known as the Consumer Credit Directive II (CCD II) - was adopted by the European Parliament in November 2023, replacing the previous Consumer Credit Directive from 2008. The critical difference: the new directive covers interest-free credits and BNPL offerings for the first time, which were previously exempt from regulation.
All 27 EU member states must transpose the directive into national law by November 20, 2025. The new rules then apply from November 20, 2026 (European Commission). Germany is currently working on implementation through an amendment to consumer credit legislation. For online retailers, this represents a fundamental change in how payment options are integrated.
From this date, all BNPL offerings in the EU must comply with the new requirements. Retailers offering BNPL payment methods should start preparing now, as technical adjustments to checkout and integrations typically take several months.
Which Payment Methods Are Affected?
The CCD II significantly expands the scope of consumer credit regulation. Previously, interest-free credits and small loans under EUR 200 were exempt. These exemptions are now largely eliminated. For shop operators, it is important to understand which of their offered payment methods are affected:
| Payment method | Affected | Not affected |
|---|---|---|
| Installment payments (interest-free) | Yes - newly regulated | |
| Invoice purchase (> 3 installments) | Yes - newly regulated | |
| BNPL (Klarna, etc.) | Yes - newly regulated | |
| Credit card (partial payment) | Yes - already regulated | |
| Instant bank transfer | Direct payment | |
| Prepayment / PayPal Direct | Immediate payment | |
| Direct debit | Single payment | |
| Invoice (single payment) | Under conditions* |
*Invoice purchase with a single payment within 50 days and without fees may be exempt from full regulation under certain conditions. The exact implementation in German law is still pending. Different rules apply to B2B transactions, as the directive primarily addresses consumer protection.
New Compliance Requirements in Detail
The CCD II introduces four central areas of obligation for BNPL providers and, indirectly, for retailers. Estimates suggest that more than 100 BNPL providers across Europe will need to adapt their business models (European Banking Authority). The industry-wide costs for compliance conversion are estimated at several hundred million euros (KPMG).
1. Creditworthiness Assessment
BNPL providers must conduct an adequate creditworthiness assessment before each credit decision. This applies even to small amounts and interest-free offerings. The assessment must be based on reliable data - for example, by querying credit reference agencies. For retailers, this potentially means longer checkout processes and possible BNPL rejections for certain customers.
2. Pre-Contractual Information Duties
Consumers must be informed about all essential credit terms before concluding the contract. This includes: total credit amount, duration, number and amount of installments, annual percentage rate (even at 0%), any late payment fees, and consequences of default. This information must be provided in a Standard European Consumer Credit Information (SECCI) form.
3. Right of Withdrawal
Consumers receive a 14-day right of withdrawal for the credit agreement - independent of the existing right of withdrawal for the purchase contract. In practice, this means: customers can withdraw from the BNPL agreement even if they keep the goods. The checkout process must present this dual withdrawal notice clearly and comprehensibly.
4. Early Repayment
Consumers gain the right to repay installments early and without penalty fees at any time. For retailers and payment service providers, this changes the calculation of payment plans, as the expected term is no longer predictable.
Credit Assessment
Mandatory creditworthiness check before every BNPL transaction - even for small amounts
SECCI Form
Standardized EU information sheet with all credit terms before contract conclusion
Dual Withdrawal Right
14-day withdrawal right for credit agreement in addition to purchase contract
Impact on Checkout and Conversion
BNPL options increase checkout conversion rates by an average of 20-30% (Juniper Research). At the same time, 42% of Generation Z and 31% of Millennials in Europe actively use BNPL services (GlobalData). The regulatory changes could impact these advantages, as additional compliance steps lengthen the checkout process.
The new requirements affect multiple points in the checkout process: the credit check may result in BNPL rejection, requiring seamless fallback logic to alternative payment methods. The SECCI form must be displayed before payment confirmation without excessively interrupting the purchase flow. The dual withdrawal notice must be placed clearly and comprehensibly.
Thoughtful UX design can integrate the mandatory regulatory information in ways that minimize conversion impact. Expandable information fields, progressive disclosure, and clear fallback logic for BNPL rejections are proven approaches. Contact us for individual advice.
Technical Preparation: Adapting Checkout and Payment
The technical implementation of the new requirements demands adjustments on multiple levels. For Shopware-based shops, a systematic preparation is recommended:
- Payment plugin audit (immediately): Review which BNPL payment methods are currently active in your shop and which providers are affected. Contact plugin manufacturers regarding planned updates for CCD II compliance.
- Checkout flow analysis (Q2 2026): Identify where in the current checkout process the new mandatory information (SECCI, withdrawal notice) needs to be integrated without jeopardizing conversion.
- Implement fallback logic (Q2-Q3 2026): Develop a seamless alternative for customers whose BNPL application is rejected. Automatic redirection to credit card, bank transfer, or other payment options prevents cart abandonment.
- Update integrations (Q3 2026): Ensure that API integrations with your payment service providers can transmit the new data fields (credit check result, SECCI confirmation, withdrawal status).
- Testing phase (Q3-Q4 2026): Test the adapted checkout process with all BNPL scenarios: approval, rejection, withdrawal, and early repayment.
The BNPL Market in Europe: Facts and Figures
The European BNPL market reached an estimated transaction volume of EUR 186 billion in 2024 and is expected to grow to over EUR 300 billion by 2028 (Juniper Research). In Germany, the BNPL share of the e-commerce payment mix stood at approximately 12% in 2024 with an upward trend (Statista). Globally, over 360 million people use BNPL services (GlobalData).
The regulation targets a market where studies show that approximately 25% of BNPL users have already missed at least one installment payment (Financial Conduct Authority). The EU sees a need for consumer protection: the apparent simplicity of BNPL offerings leads consumers to underestimate financial risk. The regulation aims to create transparency without stifling innovation.
Obligations: Retailers vs. Payment Service Providers
A common misconception: the CCD II primarily targets lenders and credit intermediaries, not retailers directly. However, online retailers are indirectly affected, as the regulation changes the technical and contractual framework for BNPL integration in shops.
| Area of responsibility | Payment service provider | Online retailer |
|---|---|---|
| Conduct credit check | Primary obligation | Provide technical integration |
| Provide SECCI form | Content responsibility | Ensure display in checkout |
| Withdrawal notice | Text creation and legal compliance | Correct integration in order process |
| Data transmission | Provide API endpoints | Implement integrations correctly |
| Fallback on rejection | Transmit status message | Offer alternative payment method |
Retailers should review their contracts with payment service providers early and ensure that responsibilities for the new obligations are clearly defined. Professional consulting helps minimize liability risks.
Data Protection and BNPL: GDPR Requirements
The creditworthiness assessment as part of BNPL transactions processes particularly sensitive personal data. The GDPR imposes strict requirements here: querying credit reference agencies typically requires explicit consent or a legitimate interest. The results of the assessment may only be used for the specified purpose and must not be stored longer than necessary.
For shop operators, this means: the checkout must transparently communicate that a credit check is being performed, and consent management must cover BNPL-related data processing. The combination of CCD II and GDPR increases compliance effort but simultaneously protects against legal risks.
Credit reference agencies may only process score values under Article 22 GDPR (automated individual decisions) when the prerequisites are met. Customers have a right to information and explanation of the decision logic. Shop operators should address this in their privacy policy.
Recommendations for Shop Operators
The regulation is no reason to remove BNPL options from your shop - on the contrary. 82% of retailers offering BNPL report higher average basket values (PayPal Commerce Insights). The key lies in timely and professional preparation:
- Check current payment plugins for CCD II readiness
- Prepare checkout flow for mandatory regulatory information
- Configure fallback payment methods for BNPL rejections
- Expand privacy policy to cover BNPL credit checks
- Review contracts with payment service providers regarding new obligations
- Update terms and withdrawal notice for dual withdrawal rights
- Train customer service staff on new regulations
- Set up monitoring for BNPL rejection rates and conversion impact
Regulation as an Opportunity for E-Commerce
BNPL regulation creates a level playing field within the EU — as does the Green Claims Directive in sustainability — and strengthens consumer trust in installment payment offerings. Studies show that 78% of consumers trust transparent payment providers more and are more likely to buy from retailers that communicate clear terms (PwC). Shops that embrace compliance early can leverage this as a competitive advantage.
The regulatory maturity of an online shop is increasingly becoming a quality indicator. Retailers offering professionally integrated payment options signal seriousness and customer orientation. Particularly in competition with international platforms, demonstrable compliance with European consumer protection standards can be a differentiating factor.
From analyzing your current payment options to integration development to CCD-II-compliant checkout optimization - we guide you through the entire process. Get in touch for an individual assessment of your payment setup.
From November 20, 2026, BNPL offerings and interest-free installment payments fall under the EU Consumer Credit Directive (CCD II). BNPL providers must then conduct credit checks, provide standardized information sheets, and grant consumers a 14-day right of withdrawal. For retailers, this means technical adjustments to the checkout process.
No, the obligation for credit checks lies with the payment service provider or lender. However, as a retailer, you must ensure that your checkout supports the technical integration for the check and offers a seamless alternative when rejected. Responsibilities should be clearly defined in your contracts.
Not necessarily. A classic invoice purchase with a single payment within 50 days without fees may be exempt from full regulation under certain conditions. Installment payments and BNPL models with multiple partial payments generally fall under the new directive. The exact national implementation in Germany is still pending.
Additional compliance steps in checkout may temporarily impact conversion. Through thoughtful UX design, progressive disclosure of mandatory information, and well-implemented fallback logic for BNPL rejections, the impact can typically be minimized. Long-term, transparency strengthens customer trust.
This is generally not advisable. BNPL options increase conversion by an average of 20-30% (Juniper Research) and raise average basket values. Instead of removing BNPL, early preparation for the new requirements and professional payment integration that combines compliance with conversion is recommended.
We analyze your current payment options, check your payment plugins for CCD II readiness, adapt the checkout flow to the new requirements, and implement fallback logic for BNPL rejections. From integration development to UX optimization, we support the entire process.
This article is based on data from the European Commission, Juniper Research, GlobalData, Statista, the Financial Conduct Authority, PwC, the European Banking Authority, and KPMG. The cited figures and regulatory details may change through national transposition of the directive.
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