CCD II in 3 Minutes: What Mid-Sized Merchants Really Need to Know

If you run an online shop and offer invoice purchase, instalment purchase or “Buy Now, Pay Later”, a new set of rules will apply from 20 November 2026: the second EU Consumer Credit Directive, or CCD II for short. It replaces the previous directive from 2008 and closes a gap that legislators had previously left open – namely the regulation of digital microloans, short-term credit, and alternative sales financing models.

For mid-sized merchants, this primarily means one thing: there are three important changes you need to know about, and a whole series of adjustments that, ideally, will largely be handled by the payment provider.

1. More payment methods will fall under consumer credit law

Until now, the rule was this: anyone granting a loan of less than €200 or offering a short-term, interest-free payment deferral was largely exempt from consumer credit law. That is now changing. In future, small-value loans, free-of-charge credit, and BNPL models will also fall within its scope.

However, there are two important exceptions that are relevant for many merchants: if you yourselves grant your customers an interest-free payment deferral of no more than 50 days – that is, without any intermediary involved – the transaction remains outside consumer credit law. For very large online providers, this period is reduced to 14 days. But as soon as a third party (for example a BNPL provider such as Unzer) fully assumes or purchases the receivable, CCD II applies – even for very small amounts.

2. Stricter creditworthiness checks – but not carried out by merchants

The creditworthiness assessment will become more thorough in substance. Until now, many BNPL and small-loan models were exempt from strict consumer credit law – in future, lenders will also have to carry out a detailed assessment in these cases. Specifically, credit may only be granted if the assessment shows that there are no significant doubts as to whether the customer will repay in accordance with the agreement. This standard already applied to traditional instalment loans; what is new is that it will now also apply to invoice purchase, BNPL, and loans below €200.

In substantive terms, the assessment will become broader: banks and BNPL providers will have to take more data into account regarding income, expenditure and financial circumstances. Certain data sources, however, are excluded – social media data and particularly sensitive data such as health information may no longer be used.

What this means for merchants is straightforward: the assessment is carried out by the lender, not in the shop. If you use a reputable payment partner such as Unzer, you do not need to make any technical changes. The effect will only become apparent after the effective date – more frequent declines are possible because the checks will be more stringent. Conversion monitoring in the first few weeks after 20 November 2026 is therefore advisable.

3. Advertising and checkout: this is where your risk lies

Under CCD II, there are two areas to which merchants should pay particular attention: advertising financing offers and pre-selected options in the checkout.

Mandatory information such as the annual percentage rate (APR), the total amount payable and a representative example is already required today. What is new is a mandatory warning notice drawing attention to the risks of taking out credit. A banner advertising “0% financing” without this information may become vulnerable to legal challenge from November 2026 onwards.

In addition, pre-ticked boxes for residual debt insurance or additional services are prohibited. If you have made your own customisations to the checkout, you must check that no pre-selected options remain active.

The good news is that consumer credit agreements may in future be concluded in text form. Anyone who previously had hybrid processes involving a final paper printout can now move to a fully digital process.

What else is important

The new directive also regulates other points that are relevant for mid-sized merchants:

• Maximum withdrawal period: In future, withdrawal from a consumer credit agreement will be excluded after a maximum of twelve months and 14 days. This puts an end to the so-called “perpetual right of withdrawal” in cases of defective notices.
• Reminder obligation for rapid contract conclusion: If fewer than 24 hours pass between the pre-contractual information and the conclusion of the contract – the standard case in online checkout – the consumer must be reminded of their right of withdrawal once again between one and seven days after the contract is concluded.
• Credit intermediary authorisation under Section 34k GewO: Anyone who commercially arranges consumer loans, including BNPL offers, requires specific authorisation. For most small and medium-sized merchants, the SME exemption applies if they only finance their own sales. Larger merchants and platforms should have this issue reviewed specifically.

What you should do now

Three steps are enough to get started:

• First, take a brief overview of your payment methods: which fall under CCD II, and which do not?
• Then, review all advertising materials – banners, landing pages, newsletters and social ads – wherever financing plays a role.
• Finally, speak to your payment partner to clarify together who will take care of which adjustments.

If you tackle the issue step by step, you can approach the deadline with confidence. And if questions arise along the way, Unzer will be happy to support you, provide straightforward advice, and help find the right solutions.