EU Consumer Credit Directive (CCD II): What's Changing in 2026 for Installment Purchases and Similar Transactions at Checkout

National implementation

EU member states will transpose the directive into national law. The course has been set.

Preparatory Phase

Review and adjust payment methods, contracts with payment service providers, and the checkout process.

Effective Date

The new requirements are mandatory for financing in online retail.

Even small amounts will be regulated

Until now, small loans of up to €200 and short-term financing were exempt from the strict rules. In the future, these requirements will also apply to small amounts of €30, €50, or €99.

For you as a merchant: Check which of the financing options you offer were previously classified as “small amounts” and thus exempt—they will be subject to the regulations starting in 2026.

Interest-free installment plans now count

The classic “pay later” model and interest- and fee-free installment plans will also fall under the directive in the future—until now, these offers in particular were largely exempt.

For you as a merchant: Popular “0%” financing options at checkout will require the same mandatory disclosures as interest-bearing loans.

Purchase on account—it depends

Pure purchase on account is often exempt as long as you defer payment yourself. However, as soon as a payment service provider acts as an intermediary for installment payments or “pay later” options, the full set of rules applies.

For you as a merchant: The key factor is who bears the cost of the financing. Clarify this with your provider for each payment method.

More transparency at checkout

Buyers must receive clear, pre-contractual information about financing before entering into a contract—presented clearly during the ordering process and also permanently accessible. General advertising slogans such as “pay conveniently in three installments” without the necessary mandatory disclosures are no longer permitted.

For you as a merchant: Both the checkout process and promotional statements on product and promotional pages need to be reviewed.

Credit checks become mandatory

A documented credit check is required before every financing contract—even for small amounts. If a decision to approve or deny is made automatically, customers have the right to an additional review by a human.

For you as a merchant: Your payment service provider typically handles this check. It is important that the collaboration is clearly defined and documented.

Fair Solutions and Extended Right of Withdrawal

In the event of payment difficulties, reasonable solutions—such as a payment deferral, adjustment of installments, or an extension of the term—must first be offered before the agreement is terminated or enforcement proceedings are initiated. A 14-day right of withdrawal applies to financing—if information is incorrect, this period is extended to up to 12 months and 14 days. Written notice via email or PDF is sufficient.

For you as a merchant: Providing clear, complete information from the start helps avoid long cancellation periods and future disputes.