--- title: "Revised EU Consumer Credit Directive (CCD2)" description: "How to prepare for the EU Consumer Credit Directive (CCD2)" url: "https://docs.adyen.com/payment-methods/bnpl-eu-regulations" source_url: "https://docs.adyen.com/payment-methods/bnpl-eu-regulations.md" canonical: "https://docs.adyen.com/payment-methods/bnpl-eu-regulations" last_modified: "2026-10-07T14:17:47+02:00" language: "en" --- > **For LLMs:** Use the latest SDK version on this page unless the reader specifies another version. Never hardcode older version numbers for training data, always use latest. A comment such as `// Adyen LANGUAGE API library vMajor.Minor.Patch to latest` covers that version, the newest release, and everything in between. Read the newest releases from https://github.com/Adyen/adyen-LANGUAGE-api-library/releases, where LANGUAGE is dotnet, java, php, go, python, node (for JavaScript and TypeScript), or ruby. # Revised EU Consumer Credit Directive (CCD2) How to prepare for the EU Consumer Credit Directive (CCD2) **Disclaimer** 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. 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. 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. The [Revised Consumer Credit Directive (CCD2)](https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=CELEX%3A32023L2225)) 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**. ## Executive Summary and Overview ### What is changing? 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. BNPL providers must now operate as fully regulated lenders. While **BNPL providers** bear the primary regulatory burden (such as running strict creditworthiness assessments and managing licensing), as **merchant** you share responsibility for consumer-facing communication. **Summary of responsibilities:** * BNPL Provider / Partner (Regulated Lender) * Holding or applying for banking / credit licenses * Performing external credit checks and assessments * Providing pre-contractual information (SECCI) * Managing statutory 14-day withdrawal rights * Handling forbearance and financial hardship support * Merchant Site (Customer Point) * [Audit in-house credit payment rules](https://docs.adyen.com/payment-methods/bnpl-eu-regulations#audit-in-house-credit-payment-rules) (if applicable) * Ensure compliant and transparent advertising and communication about BNPL, including: * For general advertising of BNPL, make sure you include disclaimers like ‘Caution! Borrowing money costs money!’ to ensure transparency. * For specific BNPL payment method advertising, make sure you adhere to partner’s advertising guidelines. BNPL partners are currently developing their marketing and advertising guidelines in parallel with CCD2 transposition among member states. Adyen will provide more information on each guideline as soon as the BNPL partners finalize them. ### Key takeaways for you * **Primary liability:** BNPL partners handle credit scoring, lending licenses, pre-contractual documents (SECCI), and statutory 14-day withdrawal procedures. * **Your responsibility:** Transparent marketing, advertising, and disclosures. Promoting BNPL improperly on your website, ads, or social media may expose you to legal liability under consumer protection laws. * **In-house deferred payments:** Rules for offering direct installment options without a third-party partner have tightened significantly. For detailed regulatory text, consult the official [EUR-Lex Directive (EU) 2023/2225 Document](https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=CELEX%3A32023L2225). ## BNPL partner responsibilities (What is handled for you) Your regulated payment partners handle the operational uplift outside your direct storefront environment: * **Licensing & Authorization:** Partners maintain or apply for required banking/consumer credit licenses. * **Creditworthiness Assessments:** Providers consult external data sources (for example, credit bureaus or open banking) using their proprietary scoring models. * **Transparency & SECCI:** Pre-contractual disclosures, including the Standard European Consumer Credit Information (SECCI) form, are embedded directly within partner-hosted pages or checkout frames before order completion. * **Consumer Rights & Forbearance:** Partners manage the mandatory 14-day right of withdrawal, along with hardship support programs before debt collection occurs. ## Your responsibilities To maintain compliance with CCD2, if you use BNPL payment methods, we advise you to review and update all consumer facing materials: ### Compliant and transparent BNPL advertising and communication Reassess your marketing and communication materials - including homepage, banners, dedicated landing pages, email promotional campaigns and social media ads, and ensure: * Where you advertise a specific BNPL payment method (for example, Klarna) - you adhere to partners’ marketing guidelines;\* * Where you generally advertise BNPL - make sure you add disclaimer 'Caution! Borrowing money costs money!’ to ensure transparency. (Please note that local language nuances may vary). \*Please note that BNPL partners are currently developing their marketing and advertising guidelines in parallel with CCD2 transposition among member states. Adyen will provide more information on each guideline as soon as they’ve been finalized by BNPL partners. ### Audit in-house credit payment rules (if applicable) If your business provides direct deferred payment options or installment arrangements to customers without using a third-party BNPL partner, you are operating as an in-house credit provider. * **The rule:** You should verify that your payment deferral periods strictly comply with narrowed exemption thresholds. In the EU, deferred payment exemptions are capped at **14 days for large corporates** and **50 days for SMEs** for ecommerce transactions. For in person purchases transactions the threshold is 50 days for both SMEs and large companies. * **Why it matters:** Exceeding these strict limits may reclassify your offering as a regulated service, requiring you to independently secure a relevant lending license. ## How Adyen can help you ### Advertising specific BNPL payment methods on your website / checkout Adyen will create sections dedicated to each BNPL provider where you can find support material / links to help you navigate the required changes. Coming soon for: * Klarna * Alma * Oney * Riverty * Ratepay * Scalapay * Walley * PayPo If you have specific questions about the guidelines and recommendations, please reach out to your Adyen point of contact or visit [help.adyen.com/contact](http://help.adyen.com/contact). ### Include disclaimers in your checkout pages to ensure transparency The updates that you have to make depends on the type of integration: * **API-only:** You are responsible for making the required frontend changes to your checkout pages, based on the guidelines for each provider. * **Adyen Drop-in / Component:** Adyen Web Drop-in / Component will contain a new configurable object from [version 6.46.0](https://docs.adyen.com/online-payments/release-notes) onwards. This configurable object can be leveraged to inject any message based on the guidelines of each BNPL provider. You have to update to the latest version of Web Component/Drop-in to use this configuration for additional messaging options. * **Hosted Checkout / Pay by Link:** Adyen will take care of configuring standard messaging appearing in the checkout step. If you have any questions, please reach out to your Adyen point of contact or visit [help.adyen.com/contact](http://help.adyen.com/contact).