{"title":"Revised EU Consumer Credit Directive (CCD2)","category":"default","creationDate":1791375467,"content":"
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Disclaimer<\/strong><\/p>\n

The content provided on this page does not represent a legal opinion or advice but is Adyen's own understanding and interpretation of laws and regulations. We do not guarantee completeness or accuracy and in case of doubt we advise you to engage independent legal advisers in a respective jurisdiction.<\/p>\n<\/div><\/div>\n

For years, Buy Now, Pay Later (BNPL) operated in a regulatory gray zone by offering short-term, interest-free micro-loans that bypassed traditional consumer credit laws. However, concerns over rising consumer debt have triggered full regulatory oversight across major markets.<\/p>\n

To enhance consumer protection and modernize digital lending, regulators are bringing short-term, interest-free BNPL services under the same legal umbrella as traditional consumer credit.<\/p>\n

The Revised Consumer Credit Directive (CCD2)<\/a>) updates EU consumer protection laws to remove previous exemptions for short-term BNPL products, and must be transposed by EU member states and fully applied by November 20, 2026<\/strong>.<\/p>\n

Executive Summary and Overview<\/h2>\n

What is changing?<\/h3>\n

Historically, short-term BNPL products (such as deferred payments or short installment plans) were largely exempt from strict consumer credit regulations. Under CCD2, these exemptions are largely removed.<\/p>\n

BNPL providers must now operate as fully regulated lenders. While BNPL providers<\/strong> bear the primary regulatory burden (such as running strict creditworthiness assessments and managing licensing), as merchant<\/strong> you share responsibility for consumer-facing communication.<\/p>\n

Summary of responsibilities:<\/strong><\/p>\n