CCD2 and Pay Later, in Plain Terms

What CCD2 is

CCD2 replaces the 2008 Consumer Credit Directive. It widens the rules so that products that used to fall outside them — including many “buy now, pay later” and deferred invoice payment services — are treated as consumer credit, with the information, creditworthiness and conduct duties that come with it.

For online shops, the practical effect is on the checkout: if a third party gives your customers time to pay, that third party becomes a creditor or credit intermediary under consumer credit law, and the cost and friction of the option is likely to change.

The exclusion for merchant-run deferred payment

Article 2(2)(h) keeps one form of “pay later” outside the directive. It covers deferred payments where all of these hold:

• the supplier of the goods or services gives the consumer time to pay, without a third party offering credit;
• the price is paid free of interest and without any other charges, with only limited late-payment charges allowed by national law; and
• the payment is made in full within 50 days of delivery of the goods or service.

For larger online sellers there is a stricter version. Where the supplier is not a micro, small or medium-sized enterprise and sells at a distance online, the exclusion applies only if a third party neither offers nor purchases the credit, payment is made within 14 days of delivery, and it is free of interest and other charges.

What this means for your shop

• If you are an SME and you run “pay within 30 days” yourself — no interest, no fees — you can stay outside CCD2.
• If a BNPL or invoice provider runs it for you, it becomes regulated credit from 20 November 2026.
• If you sell a receivable to a third party, or a third party pre-funds the order, the exclusion no longer applies.
• If you are a large online merchant, the window is 14 days rather than 50.

Kalplex is built around these conditions: it is software only, it never buys or funds receivables, it blocks interest and fees, and it caps the debit date at 50 or 14 days. See compliance guardrails.

Who counts as an SME

CCD2 refers to the EU definition in Recommendation 2003/361/EC. Medium-sized enterprises have fewer than 250 employees and either an annual turnover of up to €50 million or a balance sheet total of up to €43 million. Group structures and partner companies count towards the thresholds, so check with your accountant.