EU Consumer Credit Directive 2 Deadline Brings Buy-Now-Pay-Later into Regulated Credit Framework

European Union member states faced a binding transposition deadline of 20 November 2025 for the revised Consumer Credit Directive — CCD2 — which for the first time brings buy-now-pay-later products within the regulated consumer credit framework across the bloc. The directive requires BNPL providers to conduct affordability assessments and provide standardised pre-contractual disclosures to consumers before credit is extended, applying to credit agreements of up to €100,000. CCD2 removes the old €200 minimum threshold, so smaller loans are also covered.

Consumers using qualifying BNPL products will be entitled to the same information rights and protections that have long applied to personal loans and revolving credit facilities under EU law.

BNPL PROVIDERS FACE LICENSING REQUIREMENTS

BNPL providers operating across EU member states that are not already authorised as banks must, once the new rules apply on 20 November 2026, be admitted and registered by a competent authority in each member state where they offer regulated products, or restructure those products to fall outside the directive's scope.

The November 2025 deadline was the point of formal legal obligation for member states to adopt national laws; the new rules themselves apply to providers from 20 November 2026, when the original 2008 directive is repealed.

AFFORDABILITY CHECKS AND NATIONAL IMPLEMENTATION

By mandating affordability checks, the directive aligns the standards applied to BNPL with those that have governed personal loans and credit cards across the EU for many years.

Member states retain flexibility in how they implement the directive into national law, meaning that practical enforcement approaches and the specific form of licensing requirements may vary across jurisdictions in the initial period following the deadline.