The CCD II Checklist: 15 Points That Must Be in Place by November 2026

CCD II is not something that can be implemented at short notice. The new requirements affect different areas of the business – from legal and marketing to IT and customer service. The following checklist brings together the key points for online merchants, organised by topic.

Taking Stock

1. Prepare an inventory of payment methods.
List all payment methods offered in the shop. Which of these fall under CCD II under the new rules, and which are exempt?

2. Review contractual relationships with payment providers.
Who is the lender, who is the intermediary, and who assumes which obligations? In most cases, the BNPL provider is the lender and the merchant acts as intermediary – but this should be clearly documented in writing. Reliable payment providers will inform you accordingly and amend their contractual terms in due course.

3. Check Section 34k of the German Trade Regulation Act (GewO).
Does the business fall under the SME exemption for in-house financing? Larger merchants and platforms should actively clarify whether authorisation is required. Anyone holding authorisation under Section 34c (1) no. 2 GewO must switch to Section 34k GewO by no later than 31 May 2027. Mark the deadline in your calendar.

Advertising and Marketing

4. Review advertising materials.
Check banners, landing pages, newsletters, social ads, affiliate advertising and Google Ads – in short, anything used to promote financing. The same applies to offline advertising, such as flyers or price tags at the point of sale.

5. Add the mandatory information.
The annual percentage rate (APR), total amount payable and a representative example must be included in every financing advertisement. In addition, the warning notice must be integrated. CCD II requires a mandatory warning highlighting the risks of taking out credit. Request templates from your payment provider or legal adviser.

Technical Issues and Checkout

6. Check plugins and update them if necessary.
Do payment plugins need to be updated? The updated plugin should be running in production by October 2026 at the latest. Earlier testing in a staging environment is advisable.

7. Remove pre-selected options.
Pre-checked boxes for residual debt insurance, additional services or newsletters linked to financing are prohibited. Review the checkout process systematically.

8. Check the sequence of contractual steps.
Pre-contractual information first, then SECCI, then contract conclusion – the order must be correct and clearly structured. Custom modifications to the checkout flow may put compliance at risk.

9. Ensure SECCI is displayed.
The Standard European Consumer Credit Information must be available before the contract is concluded. In the standard setup, this is handled by the payment provider; in bespoke solutions, the responsibility lies with you.

T&Cs and Contractual Documents

10. Clarify the obligation to send a reminder in cases of rapid conclusion.
Where online contracts are concluded within 24 hours of the pre-contractual information being provided, an additional reminder of the right of withdrawal must be sent between day 1 and day 7 after conclusion. Who will handle this technically?

11. Implement the customer’s choice between paper and another durable medium.
The customer must be able to choose how they receive the contractual documents. That choice must be documented in the contract.

12. Review the T&Cs.
Update passages relating to invoice purchase, instalment purchase, financing, rights of withdrawal and pricing information, and remove references to outdated statutory provisions, old deadlines or the model withdrawal information that will cease to apply. This also includes providing a separate withdrawal notice for the credit agreement. Please note: the withdrawal notice for distance selling is not affected by CCD II – the model under Article 246a EGBGB remains unchanged. Only the notice for the credit agreement changes.

13. Review the privacy policy.
If you yourself transmit personal data to credit agencies or other service providers for the enhanced creditworthiness assessment required under CCD II, adjustments to your privacy policy or privacy notices may also be necessary.

Customer Service and Internal Processes

14. Update FAQs and help pages.
Adapt information on financing, credit checks and rights of withdrawal to reflect the new legal framework.

15. Set up conversion monitoring.
In the first weeks after 20 November 2026, actively monitor checkout abandonment rates. If there are noticeable changes, discuss them with your payment provider.