The 7 Biggest Myths about the New Consumer Credit Directive

Since it became clear that the Consumer Credit Directive, also known as CCD II, will apply in Germany from 20 November 2026, a number of half-truths have been circulating on industry blogs, LinkedIn posts, and among merchant communities. We set the record straight on the seven most persistent myths and explain what really applies.

Myth 1: CCD II only affects large banks and fintechs

CCD II applies to anyone who offers or brokers consumer credit on a commercial basis—including online merchants who have integrated a BNPL (Buy Now, Pay Later) button at checkout, furniture retailers offering instalment payments at the point of sale, and specialist retailers with their own 0% financing schemes. If you provide financing yourself, you are a credit provider. If you offer financing through a third party, you are at least a credit broker.

The difference from previous law: models that previously fell under "payment services" or "minor credits" are now included. BNPL is the most prominent example, but not the only one.

Myth 2: CCD II does not apply below 200 euros

Incorrect—this threshold has been specifically removed. The previous 200-euro minor credit limit is one of the central deletions under CCD II. Even an invoice purchase for 49 euros can be subject to the full scope of consumer credit regulation.

An exception remains for interest-free, short-term payment deferrals borne by the merchant—up to 50 days for small providers, up to 14 days for large online providers. The distinction follows the EU definition for SMEs—broadly: "large" starts at 250 employees or over €50 million in annual turnover. However, as soon as a third party (such as a BNPL partner) assumes the entire receivable, CCD II applies—regardless of the amount.

Myth 3: We now have to conduct credit checks ourselves

This only applies if you operate your own financing. In all other cases, the creditworthiness assessment is carried out where the credit is granted—by the lender, not by you as the merchant. For those using a reputable payment provider, such as Unzer, there is generally little or nothing that needs to change technically. The credit assessment becomes more thorough, but will still be conducted within the same checkout flow as before.

It is different if you provide longer-term financing yourself—that is, you are granting credit at your own risk. In that case, you must fully comply with the new requirements yourself, and the effort involved is considerable. For medium-sized businesses, this scenario is rare.

Myth 4: The standard cancellation policy still applies; it’s just an update

No, the statutory model cancellation notice for consumer credit agreements will be abolished without replacement. This means: there will no longer be an official template you can blindly rely on. In future, lenders must ensure their cancellation notices are legally compliant—taking on the associated responsibility. However, this only refers to cancellation notices for credit agreements. The cancellation notice for distance selling contracts (for online shops, for example) is not affected: the standard template for online shops remains unchanged.

Myth 5: Advertising "0% financing" is now prohibited

This is also incorrect. 0% financing remains permitted and can still be advertised. However, the advertising must include the mandatory information: annual percentage rate, total amount, representative example—this already applies today. What is really new under CCD II is the obligation to include a warning notice highlighting the risks of taking on credit.

In practical terms: anyone running banners, newsletters, landing pages, or social media ads with financing offers must review and, where necessary, adapt their advertising materials. The obligation applies wherever you advertise with specific terms.

Myth 6: Existing contracts must be updated

Contracts entered into before 20 November 2026 will continue to be governed by the old law. There is no deadline by which existing contracts must be converted to the new rules. The new rules apply exclusively to contracts concluded after the effective date.

Myth 7: CCD II is basically the same as the upcoming PSD3

These are two different sets of regulations. While they may overlap in cases of BNPL, invoicing, and instalment purchase, they regulate different matters. CCD II concerns credit, that is, the terms under which consumers can borrow money, as well as their rights and obligations. The upcoming PSD3 (together with the associated PSR) deals with payments: who may process payments, how authorisation is handled, how open banking works, and liability in the event of fraud.

What is the takeaway?

CCD II is more an extension than a revolution. Merchants with a competent payment partner like Unzer, a robust advertising process, and who review their checkout processes critically will experience 20 November 2026 with minimal disruption.

If you are unsure how CCD II affects you as a merchant or if you have other questions, please contact us—we are happy to help.