EU credit rules reach buy now, pay later from 20 November

EU credit rules reach buy now, pay later from 20 November

10 November 2026: National rules implementing the revised EU Consumer Credit Directive must apply from 20 November 2026, bringing most buy now, pay later checkout credit under a duty to assess the shopper's creditworthiness. Online retailers and the payment software behind them have ten days to confirm which of their pay-later options still fall outside the law.

Not yet independently verified. The dates and scope come from the directive itself. We have not read the German transposition act or national rules elsewhere, and how each provider will change its checkout is reported by t3n rather than confirmed by the providers. We will update this when it can be confirmed, and remove this note.

Which deferred payments stay exempt

Directive 2023/2225 applies to consumer credit agreements up to EUR 100,000, and its list of exclusions is narrower than the 2008 law it replaces. Deferred payment remains outside the rules only where a seller gives the customer time to pay with no third party offering credit, free of interest and other charges apart from limited late fees, and with payment completed within 50 days of delivery.

Large online sellers get a tighter version. Where the seller is not a micro, small or medium-sized enterprise and sells at a distance, the exemption applies only if a third party is neither offering nor purchasing the credit, and payment is due within 14 days.

That wording is the part an e-commerce team should read against its contracts. A pay-later button run by an external provider involves a third party, so the exclusion does not fit it, however short the term.

What a credit check must now contain

Article 18 requires a thorough assessment before the agreement is concluded, based on relevant and accurate information about income, expenses and other financial circumstances, and proportionate to the nature, duration, value and risks of the credit. The directive bars special category data under the GDPR. It also says social networks must not be used as an external source.

The German outlet t3n reports that users are already being asked about matters such as rent, and that the directive itself does not require that question or say how often data must be collected. Its reading is that proportionality and the GDPR principle of data minimisation pull against each other for a EUR 30 purchase, which leaves providers to decide how much to ask at checkout.

Old agreements and the changeover

Under Article 47 the 2008 directive is repealed with effect from 20 November 2026. It continues to govern agreements existing on that date until they end, with one exception. A set of articles of the new directive, including Articles 23 to 25 in part, 28 and 39, applies to all open-end agreements already running, so revolving credit products have to change for existing customers as well as new ones.

Member states were due to adopt their measures by 20 November 2025, and t3n confirms the 20 November start for Germany. Conversion rates at checkout are the commercial exposure. An added income question inside a payment flow is a step many shoppers will meet for the first time, and integrators of services such as Klarna, PayPal and Ratepay should test the new journey before the date.

Our payment processing software category lists 14 products.

Sources

• EUR-Lex: Directive (EU) 2023/2225 on credit agreements for consumers, 30 October 2023
• t3n: Neue Regeln fuer Ratenkaeufe, 9 November 2026