CCD2 partner portal

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.

The directive sets one EU-wide baseline, but each member state applies it through its own national law, so some details differ. The main differences are the exact wording, format and placement of the credit warning, how credit checks are carried out, and local rules for credit intermediaries. Klarna builds these market differences into its own flow and assets, so you don’t have to. Where your own checkout or marketing is affected, please see section ‘Advertising’ further down but always check the local rules with your legal counsel. 

For most merchants, no changes to the integration is needed. Klarna handles the credit assessment, the credit information and the new screens in its own flow, and Klarna’s dynamic assets are updated automatically. The exceptions are:

• Tokenized on-demand purchases where the consumer is present need a step-up (terms review) in your integration. Follow Klarna’s developer documentation. (See section 'Tokenized Payments')

  • Auto-renewing subscriptions need no step-up flow.

  • Keep Pay in full enabled, so that charges that can’t be funded by credit still go through.

• Your own static copy about Klarna or credit (checkout text, FAQs, marketing) is for you and your legal counsel to review, but we have provided guidelines with copy suggestions. (see section 'Advertising')

• If you integrate through a payment service provider (PSP), the PSP will ensure any integration requirements are supported.

CCD2 applies from 20 November 2026, and Klarna will be compliant before that date. Most of the changes happen inside Klarna’s own purchase flow and dynamic on-site assets, so there is nothing for you to test or switch on. There are two exceptions:

• Tokenized payments where the consumer is present, such as on-demand purchases. The step-up integration is described in Klarna’s developer documentation.

• Copy you have written or hard-coded yourself, such as payment-option labels on your own checkout, static text about Klarna or credit, and marketing materials. These don’t update automatically, so please review them with your legal counsel and update them before 20 November 2026. See section 'Advertising' for more guidance.

We recommend starting early so you have time to test and make changes. 

Please always refer consumers with questions about Klarna directly to our support.

If you need an overarching intro to CCD2 and what changes Klarna will do, please see below.

CCD2 is the EU's revised Consumer Credit Directive, which extends consumer credit rules to non-interest bearing products like Klarna's Pay Later and Pay in 3. From 20 November 2026, this means Klarna is legally required to run a documented creditworthiness/affordability assessment before offering these payment options to a consumer, and to give consumers clearer, more detailed information about the credit product they're choosing.

What this means for the Klarna purchase flow: after selecting Klarna at checkout, the consumers may see one or two extra steps — for example, being asked about their income or expenses, and/or being asked to accept credit agreement terms & SECCI before they can complete the purchase.

What your customer support team needs to know:

• In the purchase flow, Klarna will at times need to ask the consumer for extra information regarding their finances e.g. their income and expenses also referred to as affordability questions. Note, the majority of consumers will never be asked any questions at all, only in very few cases will questions about affordability i.e. consumer income and expenses be presented.

• The affordability questions are triggered by Klarna, not by your business, and they are a legal requirement under EU consumer credit law — not a sign of fraud, a scam, or a system error.

• If a consumer contacts your support team confused or concerned about being asked for income/expense information during checkout with a Klarna payment option, your agents can reassure them this is a legitimate, standard part of Klarna's checkout process and safe to complete.

• Any information the consumer provides is collected and processed directly by Klarna, in line with GDPR and Klarna's own privacy policy. It's used solely to carry out the required affordability assessment and is not shared with your business or any other third party.

• Your agents should not attempt to explain Klarna's assessment criteria, decisioning logic, or resolve issues with the checkout flow itself — please direct consumers with further questions, or who are having trouble completing the flow, to Klarna consumer Service [link].

• Klarna owns this flow end-to-end, and it will be updated by Klarna as regulatory requirements evolve, so your support scripts won't need to track its details.