Starting November 20, 2026, the new EU Consumer Credit Directive (CCD II) will take effect—and, for the first time, it will also cover interest-free installment payments, “Buy Now, Pay Later” (BNPL), and small loans under €200. Online retailers have just over five weeks to review payment methods, checkout texts, and promotional materials—in time for Black Friday preparations, during which financing promotions traditionally play a major role. Here’s the checklist.
At a Glance
- Deadline: November 20, 2026: From that date on, the new rules of Directive (EU) 2023/2225 (CCD II) will apply; the German implementation law was passed—after delays—and the effective date is set (as of August 2026).
- Covered for the first time: interest-free installment payments (“0% financing”), BNPL, loans under €200, and—under certain conditions—purchase on account.
- Key obligations: creditworthiness assessment, clear pre-contractual information at checkout, transparent advertising, and a 14-day right of withdrawal.
- The main burden falls on payment providers —but merchants must review advertising, checkout wording, and provider communications.
- 5-point checklist for merchants: see below.
What will change on November 20, 2026, for installment purchases and BNPL?
The scope of consumer credit law will be significantly expanded: Until now, interest-free and fee-free loans, as well as loans under €200, were largely exempt—and it is precisely in this gap that BNPL offers and “0% financing” have flourished. Starting November 20, 2026, these payment models will be subject to regulatory obligations: The lender must assess the customer’s creditworthiness (even for small amounts), provide pre-contractual information in a standardized format, and the consumer will have a 14-day right of withdrawal regarding the credit agreement. Advertising will also be more strictly regulated: Financing offers must be advertised with clear mandatory disclosures and warning notices—the blanket slogan “Buy now, pay later” without further context will no longer suffice. We had already introduced the directive in June 2026; this article is the countdown update with the final implementation status—you can find all legal articles in our news overview.
Does purchase on account fall under CCD II?
It depends on who grants the payment deferral. If the merchant itself defers the purchase price—without interest, without fees, and with payment due within the specified period—traditional purchase on account remains exempt under certain conditions. If, on the other hand, the purchase on account is processed through a third-party provider (such as a payment service provider that assumes the receivable and grants the customer the deferral), the exemption does not apply—in that case, the new obligations apply. Since, in German e-commerce, purchase on account is overwhelmingly processed through payment service providers, merchants should assume that their purchase on account option is affected and actively inquire with the provider.
| Payment Method | Classification effective November 20, 2026 |
|---|---|
| Installment purchases with interest | Already regulated—remains so; certain obligations will be tightened. |
| 0% financing / interest-free installments | Newly covered: creditworthiness check, disclosure requirements, right of withdrawal. |
| BNPL (“Buy now, pay later”) | Now covered—regardless of the amount. |
| Small loans under €200 | Now covered—the previous de minimis threshold no longer applies. |
| Purchase on account via payment providers | Generally reported—check with the provider for classification. |
| Purchase on account directly from the merchant (interest-free and fee-free) | Still exempt under certain conditions. |
| Instant payment, card, digital wallet, prepayment | Not covered—no credit element. |
What obligations apply to the payment provider—and what obligations apply to the merchant?
The main burden lies with the lender. If your store offers financing through external providers such as Klarna, PayPal, or other payment service providers, these providers are responsible as lenders for credit checks, pre-contractual information, and contract drafting—the providers adapt their terms accordingly. However, this does not relieve the merchant of responsibility: promotional statements in the store (“0% financing,” “pay in 3 installments”) are the merchant’s own statements and must comply with the new advertising guidelines; checkout texts and payment method descriptions must not contradict the provider’s communication; and where the merchant presents financing terms and conditions themselves, the presentation must be complete and accurate. In short: The provider is restructuring the credit terms—the merchant is tidying up their storefront.
What do online merchants need to do now? The 5-point checklist
- Take inventory of payment methods: What financing and deferred payment options does the store offer—installment purchases, BNPL, purchase on account, down payment? Who is the legal lender in each case?
- Obtain provider statements: Get written confirmation from each payment provider regarding how they are implementing CCD-II requirements and what changes will occur in the checkout process.
- Review checkout wording: Compare and adjust payment method names, descriptive texts, and notices in the ordering process to match the providers’ guidelines.
- Review promotional materials: Check banners, newsletters, ads, and product page notes related to financing for compliance with the new mandatory disclosures and warning notices—before setting up for Black Friday.
- Define a process for rejected financing requests: Due to the requirement for credit checks, there will be more rejections—the checkout process should then clearly guide customers to alternative payment methods, and support staff should be familiar with the standard language to use.
The XONIC Shop System is integrated with 19 payment providers; payment method descriptions and checkout notices can be managed in the backend for each payment method, allowing customized wording to be implemented without any programming effort. The EU cancellation button is also already integrated—the guide to the cancellation button explains how to set it up; the feature overview provides an overview of the payment and checkout functions.
Note: This article does not constitute legal advice. Your payment provider and specialized law firms can provide binding clarification on how CCD II applies to your specific payment offerings.
Frequently Asked Questions About CCD II in E-commerce
Sources
Stephan Dunger
Stephan Dunger is one of the brains behind the XONIC store system. He has been developing the platform together with the team since 2012 - from the database to the interfaces to the checkout.
A passionate programmer, technical mind and consultant at the same time: with his in-depth knowledge of store systems and e-commerce, Stephan combines the depth of a developer with an eye for the big picture. Together with the XONIC team, he shapes the technical direction, consistently thinks about functions from the retailer's perspective and advises on customized solutions.
The result is software with a face: customers don't get an anonymous provider, but a direct line to the people who develop XONIC. Pragmatic, fast and at eye level.
