From 20 November 2026 the revised EU Consumer Credit Directive (Directive (EU) 2023/2225, often called CCD2) applies across the Union. The headline change for lenders: short-term, interest-free buy now, pay later products lose the exemptions that kept them outside consumer credit rules. The same week, Germany and other member states bring their national versions into force.

What changes

  • Creditworthiness checks become mandatory for most BNPL products, with tighter rules on what data may be used.
  • Customers get a right to human intervention when a decision is made automatically using their personal data.
  • Pre-contract information and the right of withdrawal must be shown clearly, and some duties can reach merchants’ own checkout pages.
  • In some countries providers need a licence; in Denmark, for example, a company that applies by 20 November can keep operating while the application is reviewed.

What it means at the checkout

A credit check adds a step and some declines. Merchants and providers will need a fallback, so a customer who is not approved can still pay another way instead of abandoning the basket. National laws decide many details, including exactly what a checkout must display, so lenders should confirm their setup with legal counsel in each market.

A practical checklist

  • Add a creditworthiness step that runs in seconds, using bureau and bank data where allowed.
  • Store the reasons behind each automatic decision, so staff can explain it and a person can review it on request.
  • Version disclosures and consents, and log which text each customer saw.
  • Give merchants a clear status for every order: approved, declined, under review, so the checkout can offer another payment method.
  • Plan limits and affordability rules per country, since national transposition differs.

In lendhero, decisions are explainable by design: each one stores the rules and data behind it, consents are versioned, and BNPL limits, checks and disclosures are set per product and country in the admin panel.

Sources: Directive (EU) 2023/2225; summaries by Taylor Wessing, Adyen, Unzer and Xpollens.

lendhero solutionBNPL and POS lendingInstalments at checkout and in store, with merchant portals and payouts.