Legislation on the presentation of payment methods in Sweden (Lagen om betaltjänster)

The information we provide on this page is meant to help you prepare for the Swedish Presentation of Payment Methods Law (Swedish: “Presentation av betalningssätt vid marknadsföring av betaltjänster online”). This guide is intended to:

• Help you understand whether or not the legislation concerns you.
• Cover Adyen's recommendations of making your checkout compliant.
• Provide instructions for each integration.

Does this regulation affect your business?

The law for the presentation and marketing of payment methods is a new legislation which affects how payment methods must be ordered for online volume processed in Sweden.

If your answer to any of the below criteria is yes, you will need to review your checkout and make changes to be compliant.

• You process in SEK.
• You have a Swedish entity.
• You have a Swedish domain (for example .se or .nu).
• You actively market to a Swedish audience.
• You have 1,000+ Swedish shoppers a month (according to address, IP address, or issuer).

How do the regulations affect your business?

Due to a high increase in credit debt in Sweden, new legislation is being enforced to regulate how payment methods are presented. The aim is to decrease the number of unplanned or unnecessary purchases on credit, by requiring the following:

• Credit options should not be presented first. For example, you can't place invoice first, or refer to all cards as credit cards. For more information on how to handle cards, see our recommendations.
• Credit options must not be prefilled. For example, you can't move invoice down the list of payment methods, but have it preselected.
• Credit options should not be marketed to the consumer by a payment provider or merchant. Also, the consumer should not be incentivized to select a particular payment method (for example, giving 10% off if you pay with a specific payment method).

Credit options

Payment methods that are considered to be credit options and should therefore not be presented first include:

• Credit cards, for example American Express, China UnionPay, Discover, Diners, JCB, Mastercard, Visa, and others. Please note that the majority of issued Visa and Mastercard cards are debit cards. If you process card payments in Sweden, you will need to follow the legislation.
• Klarna pay now, Klarna pay later, and Klarna Pay over time.
• PayPal
• Wallets that can include credit, such as Apple Pay, Google Pay, and Samsung Pay.

Adyen's recommendations for compliance

To help you comply with this legislation, Adyen has developed one default recommendation and two fallback recommendations. Check the technical guidance to see what changes you need to make for the default option.

If your checkout is controlled by Adyen, and we set the order of payment methods, the default option 1 will be implemented. Check the technical guidance to see if any action is required from you.

If you control the order of payment methods in your own checkout, you can choose any of these three options, but you must make the changes yourself.

Option 1

• Cards are presented as the first payment method option.
• Cards are clearly labelled Card payment or a neutral equivalent, and not credit cards or credit / debit cards.
• You use clear UX to present debit cards first, either by:
  • Displaying the logos of pure debit cards (for example Maestro or VPay), debit and credit cards (for example Mastercard or Visa), and pure credit cards (for example American Express, Diners) in such a way that debit is presented first (left to right or top to bottom).
  • Clearly stating that customers can pay with debit cards or credit cards, with debit stated first.

Example:

Option 2

Cards are presented as the first payment option, with debit cards and credit cards split out over two lines:

• The first line should be labelled Debit card or equivalent.
• The second line should be labelled Credit card or equivalent.

Example:

Fallback: option 3

• The first line presents a pure debit option, such as Swish, Trustly, or gift cards.
• The first line should not be a credit option.

Example:

What happens if the recommendations are not followed?

If you control the payment order in your checkout and you have not implemented these recommendations, you may be in breach of the terms and conditions. Legal repercussions may be forwarded from Adyen to you, including fines or a cease in processing.

Technical guidance for compliance

Option 1

These instructions help you implement option 1 if your payment form UI uses:

• A non-customized Adyen front-end integration
• A customized Adyen front-end integration
• An Adyen-maintained plugin
• HPP (Hosted Payment Pages) solution

Non-customized Adyen front-end integration

All Adyen out-of-the-box integrations (which you have not manually customized) have been updated to support the new legislation.

This includes the following:

• Drop-in: Requires /paymentMethods version 49 or later.
• Web SDK: Backwards compatible for all versions.

Customized Adyen front-end integration

If you have customized your Adyen integration, you will need to update your integration to meet the new legislation. You can find our recommendations for this here.

The following Adyen front-end integrations allow for customization:

• Drop-in
• Components
• Web SDK

Adyen-maintained plugin

If you are using one of the following Adyen-maintained plugins, you may need to update your plugin:

• Adobe Commerce:
  Version 8: In your Adobe Commerce admin panel Card Payments configuration section, set the Title to Cards.
  Version 9: From v9.0.3, the checkout page uses Cards by default. For earlier versions, run the following query in your database:

  UPDATE core_config_data t
  SET t.value = 'Cards'
  WHERE t.path ='payment/adyen_cc/title';

• Salesforce Commerce Cloud, depending on your integration type and version:
  1. Composable Storefront: Use version 1.1.0 or later, these versions display the card input field as Cards.
  2. SFRA: version 24.1.0 and later display the card input field as Cards according to your locale, we recommend to update to the latest version available. On earlier versions, adjust the card input field label in your checkout form to display Cards or Card payment.
  3. SiteGenesis: On version 20.1.0 and earlier, rename the radio button called Credit card to Cards or Card payment. On versions 22.1.0 and later, adjust the card input field label in your checkout form to display Cards or Card payment.
• SAP Commerce, changes will be included in an upcoming release, scheduled for mid June.
• PrestaShop, all versions: No changes are needed.
• Netsuite, all versions:
  • If you want to continue processing in Sweden, change the order of payment methods so that a credit option is not presented first. For instructions, see SuiteAnswers or contact Netsuite.
  • If you do not want to continue processing in Sweden, exclude Swedish language and SEK currency as options for the NetSuite-hosted checkout. For instructions, see SuiteAnswers or contact Netsuite.

If you are on a plugin not maintained by Adyen, such as Centra, Askås, Wikinggruppen, VTEX, you need to contact the platform for instructions on how to proceed.

Hosted Payment Pages solution

If you are using Hosted Payment Pages (HPP), we recommend that you upgrade to one of our newer integrations.

If you continue to use our HPP, you need to make sure that the payment methods are in the right order on your HPP skin. For instructions on how to change the order of the payment methods, refer to Configuring skins.

Option 2

To implement option 2, see the instructions for your integration type:

• Components for Web or iOS
• Drop-in for Web or iOS
• API-only

Frequently asked questions

Which payment methods does Adyen recommend presenting first?

In line with our recommendations above:

• The first line is a debit option.
• After the first debit option has been shown, you can present remaining payment methods in any order you choose within the framework of your integration.

How should transactions with saved payment details be treated?

If the saved payment method is a debit option, any logic can be used to show this to the shopper, and the legislation will not bring any changes.

If the saved payment method is a credit option, the following applies:

• Payment details saved before July 1, 2020 are not affected by the regulation. This means that consent for using the saved payment method will not need to be renewed.

• For new transactions after July 1, 2020:

  • The first transaction. Customers that enter their details after July 1, 2020 need to be presented with a checkout in line with the recommendations above. If you want to save a customer's preferred payment method after July 1, 2020 for an affected Swedish checkout, the customer will need to actively make a selection to have the payment method saved. Active selection means that the customer has to select or tick that they want their details saved.

  • Subsequent transactions. If the customer has actively selected to save their payment details, credit options can be presented first or used automatically, but the consumer needs to have the option to switch payment methods should they wish.

Adyen is not my only payment provider. How do I know which changes I need to make?

This legislation only concerns volume that is processed online in Sweden. Follow the Adyen recommendations if you use Adyen as your payment provider for online volume in Sweden.

If you use multiple payment providers to process online payments in Sweden, the following applies:

• Adyen with M-level, C-level or R-level payment methods: follow the Adyen recommendations.
• Adyen with another payment provider, where Adyen is used to present the first payment method in the Checkout: follow the Adyen recommendations.
• Adyen with another payment provider, where Adyen sets the logic for the order of payment methods: follow the Adyen recommendations.
• Adyen with another payment provider where the other provider sets the order of payment methods, but the Adyen payment method is not presented first: follow their recommendations.

If you have received multiple recommendations, use the above principles to determine which ones you should follow.

Checklist: are you ready?

1. Check whether or not your business is affected by the legislation.
2. Read and understand Adyen's recommendations.
3. Check what technical changes will or will not be made for your specific integration or plugin.
4. If you have to make manual changes, identify which option is best for your business.
5. Implement the required changes and test.
6. When your checkout has been updated, check that it does not have any of the following:
   • Credit presented first (for example “credit card”, “invoice” or “installments”).
   • Debit card presented first while labelled “credit cards”.
   • Credit of any kind prefilled or preselected.

If you have any questions, contact your Adyen Account Manager, or our Support Team.