How do the 2026 consumer credit rules affect invoice and BNPL?
From November 20, 2026, BNPL offers become regular consumer loans that require a creditworthiness check whatever the amount. Invoices financed by providers such as Klarna or Ratepay are covered, while a merchant's own free invoice due within 50 days (14 days for large online sellers) stays outside the rules.
In detail
On November 20, 2026, Germany applies the EU's revised consumer credit directive. Buy now, pay later offers become regular consumer loans, with creditworthiness checks and full cost disclosure, even for small amounts.
What is covered
Invoices financed by specialists such as Klarna or Ratepay, which buy the receivable and take the risk, fall under the new rules. A merchant's own invoice stays outside them only if it is free, involves no third party and is due within 50 days, or 14 days for large online sellers.
Why it matters in Germany
Germany is the home market of pay later. Purchase on invoice took 26.1% of online retail turnover in 2025 and installments another 4.7%. Any change to invoice flows therefore touches a large share of German e-commerce.
- Expect more declined invoice requests after credit checks.
- Expect new checkout steps and disclosures.
- Expect providers to adjust their offers and limits.
What it means for payment operators
Operators serving German merchants should check with their invoice and BNPL partners how flows change, and make sure a fallback method appears when an invoice request is declined. Offering PayPal, direct debit and cards next to invoice keeps the sale when credit is refused.