This is not legal advice. This guide explains the current understanding of the revised Consumer Credit Directive (CCD2) and outlines the obligations that we will have under these new requirements. While we do not anticipate significant changes for you, for binding interpretations — including how the rules apply to a specific business, market, or your individual setup — consult your own legal counsel.
Page last updated: 9/Sep/2026
CCD2 partner portal
Plain-English guidance on the revised Consumer Credit Directive for Klarna partners to support readiness and compliance.
About CCD2
CCD2 is the revised Consumer Credit Directive. Its main change is that Buy Now Pay Later (BNPL) — short, often interest-free options like Pay in 30 days and Pay in 3 instalments — is formally treated as consumer credit across the EU, alongside traditional credit products. That brings clearer pre-purchase information, affordability checks, and consumer rights into scope for BNPL in the same way they already apply to longer-term credit.
The requirements of CCD2 regulate the providers of BNPL — i.e. Klarna — not the merchants offering these payment options. This means Klarna is primarily responsible for readiness and compliance.
CCD2 is what's known as a full harmonisation directive — this means the implementation across all EU27 must be broadly consistent. However, there will be some slight nuances in application between markets.
BNPL is recognised in CCD2 as a low-risk product with genuine utility when offered responsibly. The rules are calibrated to the credit's nature, duration, value, and risk — not applied as a one-size-fits-all package.
"Necessary and proportionate to the nature, duration, value and risks of the credit for the consumer" — Directive (EU) 2023/2225, Article 18(3).
In practice, short, low-value, interest-free BNPL faces lighter obligations than longer-term consumer credit.
The EU-wide application date is 20 November 2026.
Member states were required to transpose CCD2 into national law by 20 November 2025. The majority missed that deadline and are now implementing at pace.
Markets where transposition is complete and the final national package is known: Denmark, Finland, France, Germany, Hungary, Italy, Slovakia, Sweden.
These are the markets where we know what the final package will look like. We expect more markets to cross the transposition line soon, and we will continually update this portal as necessary to reflect changes in those markets.
Regardless of national progress, Klarna is working on the assumption that all CCD2 rules apply from 20 November 2026 across the entire EU27, and we are preparing on that basis.
For agreements with consumers: the new rules apply to credit agreements concluded after the application date. Agreements concluded before that date continue under the rules that applied when they were entered into.
BNPL sees the largest change — it is brought fully into scope under CCD2 for the first time. Longer-term financing was already covered by the existing Consumer Credit Directive, but those products also receive updates on creditworthiness checks, pre-purchase disclosures, and treatment of shoppers in financial difficulty.
Information disclosure — standardised credit information shown before purchase, with key terms, costs, and rights presented clearly.
Credit assessments — proportionate creditworthiness checks for every BNPL transaction, based on verified financial data.
Missed payments — early detection of financial difficulty, forbearance measures, and debt counselling referrals.
Financial promotions — BNPL ads must include borrowing-cost warnings; misleading messaging is prohibited.
Credit intermediation — in most cases merchants are not classified as credit intermediaries under CCD2; Klarna owns the compliance obligations as the regulated lender.
Each affected Klarna product is being updated to comply before the application date. Partners do not need to take action on the product flows themselves, but should expect updated checkout copy, messaging assets, and disclosures from Klarna ahead of November 2026.
Licensing
No — Klarna's standard offering does not require a credit intermediary licence.
Klarna is the licensed party. You're offering Klarna as a payment method, not granting credit or brokering credit agreements yourself, so the regulatory obligations sit with Klarna. This stays the same under CCD2.
If a merchant receives an economic benefit for offering credit, there's a risk of being treated as a credit intermediary.
Becoming a credit intermediary requires several conditions to be met together, along with an economic benefit. Examples of activities that can contribute include:
Receiving a revenue share or other economic benefit tied to credit being granted
Actively promoting or advertising the credit option, beyond presenting it neutrally at checkout
Advising shoppers on which credit option to choose, or steering them toward financing
Branding the credit as the merchant's own product
Helping shoppers with credit applications or preparatory paperwork
These are examples — depending on how each is implemented, and on whether several appear together rather than just one, a merchant's activities may or may not cross the line. Standard Klarna setups are designed to keep most of these triggers clear.
If certainty is the priority, the cleanest way to remove the question entirely is to move to a setup without an economic benefit. We're happy to talk through what that could look like.
Credit checks
Credit providers will need to assess every shopper before approving a credit-funded purchase. CCD2 makes this requirement formal for Buy Now Pay Later too. The shopper experience stays designed for speed.
Klarna already runs affordability checks tailored to the size and type of purchase. Under CCD2 that check is formally required for BNPL.
Purchase flow and consumer experience
Yes, for BNPL but only in minor ways. The overall shopper experience remains smooth.
To comply with the new rules, Klarna will update the screens shoppers see when selecting a credit payment option — for example, how key information is presented before confirmation. These adjustments happen within Klarna's flow that's already embedded in your checkout.
Tokenized Payments
Yes, if a saved payment method is used for a Klarna credit product. Before each charge, the consumer may need to review and accept the credit terms. In some cases they may also need to give us more affordability information.
Klarna handles this with a zero-friction terms acceptance via a step up flow, shown to the consumer before the charge is confirmed. Saved payment methods used for Pay in full are not affected.
Subscriptions and other charges made when the consumer is not present cannot show a terms review. For these, Klarna will offer the consumer a separate line of credit that covers their subscriptions — both the ones they already have and new ones.
If the consumer does not take up that offer, their subscription payments switch to Pay in full. This is by design and in line with our tokenized payments product. Klarna's tokenized payments work across different payment options, so the charge still goes through and the subscription continues without interruption.
Make sure Pay in full is enabled. If a charge cannot be funded by credit and no Pay in full option is available, the charge fails and no order is created.
If the consumer is not present (e.g. ordinary subscription where a subscription auto renews) on session you do not need to implement the step up flow.
If the consumer is present (e.g. on-demand sales), support the terms review via a step up flow in your integration. Review integration guidelines on Klarna Docs:
HPP
(Note: These are the links relevant for Klarna Payments (KP) merchants, there is no dedicated page on just step ups, as step us are now an integrated part of the integration.)
By 20 November 2026. The integration changes are small, but start the integration adjustments well ahead of that date so there is time to test.
In store
In most standard setups, no dedicated CCD2 training program is required for store staff.
What matters is that staff present Klarna as a payment option neutrally and do not advise consumers on credit choices. If your in-store model includes active promotion or sales scripts around credit, review that setup with your legal team and your Klarna contact.
My contractual terms with Klarna
There are no fee changes that come from CCD2 itself.
If your commercial terms ever change for other reasons, that is communicated separately through your normal account contact at your credit provider. It is not tied to this regulation.
Returns and complaints
With Klarna, cancellations and returns are handled the way they are today — through your normal returns process. The credit provider settles the credit side with the shopper.
The right of withdrawal that consumers already have for credit agreements under the existing rules continues under CCD2, with some adjustments. For credit-funded purchases it's handled between the credit provider and the shopper, so the practical day-to-day flow for returns and refunds doesn't change for the merchant.
No — we don't expect any meaningful impact on how returns work today.
No change from how you operate with Klarna today.
What does change is that the credit provider's collection process will follow the new consumer-protection requirements — for example, around how shoppers in financial difficulty are treated. The merchant doesn't need to do anything here.
If it's about the product or the order, handle it as you do today. If it's about the credit-funded payment, send the shopper to the credit provider's customer service.
This split stays the same after CCD2. Klarna's app and website make it easy for shoppers to raise payment-related issues directly with Klarna.
Advertising
If you are leveraging Klarna's dynamic assets to talk about the offering, Klarna ensures compliance.
CCD2 sets clearer rules for how credit-related advertising must be presented — for example, what key information appears next to a "Pay later" or "Pay in 3" promotion. Credit providers will refresh the on-site messaging (sometimes called On-Site Messaging, or OSM) and share the new assets before 20 November 2026.
Information disclosures
Yes. All credit granted by a third-party provider will be regulated under CCD2 regardless of whether there's any cost or interest attached.
The exact wording isn't fully fixed at the EU level. It's typically set by national-level regulations, and where similar warnings are already in place locally, the same wording is likely to carry over.
The notice must cover three things: that credit entails costs, the risks of debt, and where to get budget and debt counselling. The precise phrasing is usually set at country level — and in markets where an equivalent warning already exists, it's likely the same wording will be reused under CCD2.
Not in every journey or market, but whenever CCD2 requires pre-contract credit information, the SECCI format (or local equivalent implementation) is the baseline.
Klarna will determine when SECCI is required for each product and market and present it in the flow where applicable. Merchants do not need to build SECCI logic into their own checkout.
The credit warning requirement is tied to advertising or presenting credit payment options, not to every generic mention of Klarna.
If messaging references specific credit offers (for example, Pay in 30 days or Pay in 3), required disclosures must be shown. Klarna-provided on-site messaging assets are designed to include the right disclosures for each market.
Links
Official text: Directive (EU) 2023/2225 on EUR-Lex — consolidated CCD2 text in all EU languages.
Key dates: entered into force 19 November 2023; transposition deadline 20 November 2025; application date 20 November 2026.
National implementation: contact the financial-services regulator in your market.
For binding legal questions, consult your own legal advisor.