20 November 2026
From this date, Germany applies the new rules of the EU Consumer Credit Directive (CCD II). Buy Now Pay Later from Klarna, PayPal or Riverty is then treated like a consumer loan. The implementing law is already in force in Germany and has been published in the Federal Law Gazette since 18 May 2026 (BGBl. 2026 I Nr. 139).
What is BNPL and why is it being regulated?
With Buy Now Pay Later (BNPL) you buy now and pay later, usually by invoice within 30 days or in several installments. In Germany you mainly know it from Klarna, from PayPal (pay in 30 days and installments) and from Riverty, which used to be called AfterPay.
For a long time, many of these offers did not fall under the strict credit rules, because they were interest-free or stayed below certain amounts. The EU saw a risk in this: people who buy in installments in several places at once quickly lose track. A BaFin survey from April 2025 found that 14 percent of BNPL users had lost track of their open bills. That is exactly where the new regulation steps in.
The key changes, step by step
Small amounts now fall under the credit rules
Until now, consumer-credit rules only applied from 200 euros. That lower limit is removed. From November 2026, smaller amounts also fall under the Consumer Credit Directive, while the upper limit rises to 100,000 euros.
Example: A 50-euro Klarna installment purchase will be treated like a consumer loan, because Klarna acts as a third-party provider.
BNPL providers come under BaFin supervision
Klarna, PayPal and other BNPL providers will need authorisation and will be supervised by BaFin. This does not turn them into banks, but they must follow the credit rules.
What does that mean? More transparency, a real affordability check and a supervisor that can step in when rules are broken.
Mandatory affordability check
Before an installment purchase, the provider must check whether you can likely afford the payments. The check must be proportionate and in Germany often runs through the SCHUFA or another credit bureau.
Important for newcomers: Without a SCHUFA history the check can be harder. Learn how to build a credit history in our SCHUFA guide.
14-day right of withdrawal
The credit agreement behind a BNPL purchase gets a 14-day right of withdrawal, no reason needed. If the mandatory information is missing, the window extends but ends at the latest 12 months and 14 days after signing.
How it works: You withdraw informally, an email is enough. The credit agreement is then reversed.
Mandatory warning in advertising
BNPL advertising must include a clear warning, along the lines of "Caution: borrowing money costs money." The exact wording follows from the law.
The goal: You should see at a glance that even an "interest-free" installment plan is a loan.
What stays allowed and what is exempt?
BNPL is not disappearing. You can still pay by invoice or in installments. There is even a narrow exemption: if a seller grants you an interest-free, fee-free payment deferral of no more than 50 days, it does not fall under the strict credit rules. For pure online sellers that are not small or medium-sized businesses, that limit drops to 14 days.
Good to know: the legal basis
The basis is EU Directive 2023/2225 (CCD II), in force since November 2023, applying from 20 November 2026. Germany has written it into its Civil Code (Bürgerliches Gesetzbuch), including sections 491, 492 and 506 BGB.
Instead of several BNPL plans: compare a fair installment loan
If you are planning a bigger purchase, a single installment loan is often cheaper and clearer than several parallel BNPL plans. Comparing is free and non-binding, and the request is SCHUFA-neutral.
What the new rules give you
- Protection from over-indebtedness: thanks to the affordability check, installment plans go mainly to people who can repay them.
- Clear costs: all fees and the annual percentage rate must be stated upfront.
- Withdrawal right: 14 days to reverse the agreement.
- Supervision: BaFin oversees the providers and can step in when rules are broken.
Practical tips for you
- Keep track: don't use several BNPL services at once, it makes your debt hard to see.
- Note the dates: don't miss a due date, or late fees follow.
- Check alternatives: compare an installment loan or a credit card with fixed terms.
- Plan your budget: only buy what you could afford without BNPL.
Timeline of the regulation
The EU adopts the new Consumer Credit Directive (CCD II, Directive 2023/2225).
Germany passes the implementing law. It is published in the Federal Law Gazette on 18 May 2026.
The new rules apply. All BNPL providers must follow them from this date.
Conclusion
The new BNPL regulation strengthens consumer protection. Checkout at Klarna and others may take a little longer, but you get clear costs, a real check and a withdrawal right. As a newcomer in Germany, it pays to use BNPL deliberately and keep an eye on your own credit standing. For bigger purchases, an installment loan is often the better choice.