CCD2: What is changing for Buy Now, Pay Later?

New European consumer credit requirements under CCD2 will also apply to Buy Now, Pay Later (BNPL) products.

The changes are designed to give consumers clearer information and stronger protection when using credit products.

What is changing?

The main changes include:

Clearer information before purchase
Customers will receive clearer and more standardised information about important credit terms, costs and their rights before completing a purchase.

Creditworthiness checks
BNPL purchases may be subject to proportionate creditworthiness checks based on verified financial information.

Support in case of payment difficulties
The new requirements strengthen the measures available to identify and support customers who experience difficulties making their payments.

Changes to advertising and promotions
BNPL advertising and promotional content must meet additional requirements. This includes clearer information about borrowing costs and restrictions on misleading messaging.

Updates to the checkout experience
Affected BNPL products will be updated to meet the new requirements. This may include changes to checkout wording, disclosures and customer-facing messaging.

What does this mean for me as a merchant?

In most cases, you do not need to make changes to the BNPL product flow yourself.

However, you may notice updates to:

• checkout wording
• credit information and disclosures
• customer-facing BNPL messaging
• marketing and promotional materials

Do I need to take action?

No immediate action is required if you are using Unzer direct links in your integration or marketing materials.

If you use your own links for BNPL materials on your website, in your checkout or in marketing campaigns, we recommend checking that you are using the latest approved versions when updated materials become available.

When will the changes take effect?

Affected products and customer-facing information are being updated ahead of the CCD2 application date in November 2026.