Kalplex1. Not a “third party offering credit”
The CCD2 exclusion requires that the merchant gives the consumer time to pay without a third party offering credit — and, for large online merchants, without a third party purchasing it. Pure software that helps the merchant run its own option is very likely fine. The moment a provider pays the merchant before the shopper pays, or buys the claim, it is offering or purchasing credit.
That is why Kalplex's business model is a subscription and a per-transaction fee charged to the merchant. We never earn a margin on the receivable, because we never own it.
2. Who runs the debits
If the merchant's own bank or payment service provider collects the debits under the merchant's own SEPA creditor identifier, the software provider doesn't need a payment licence. If the money flowed through the software provider's account, it would need one — or a licensed partner.
With Kalplex, debits are collected by GoCardless, a regulated payment institution, through the merchant's own GoCardless account and paid out to the merchant's bank. Kalplex sends instructions through GoCardless's API with the merchant's permission and never receives the funds. See money flows & licensing.
What we ask of merchants
- Get a lawyer's opinion in your first target country — national implementations differ.
- Don't sell or factor your pay-later receivables while using the CCD2 exclusion.
- Don't add interest or fees for paying later.
- Keep the debit within 50 days of delivery, or 14 if you're a large online merchant.