Who runs your invoice option today?
Most German shops don't run “Kauf auf Rechnung” themselves. A payment provider checks the shopper, pays the shop and collects from the shopper later. That provider is giving — or buying — credit, and from 20 November 2026 that falls under consumer credit rules.
Expect your provider to respond: more checks at checkout, new disclosures, different fees, or withdrawing from some segments. Ask them now what will change (see questions for your BNPL provider).
The merchant-run alternative
CCD2 still excludes deferred payment that the shop gives itself, free of interest and charges, paid within 50 days of delivery (14 days for large online sellers). You can keep invoice-style payment if you run it — and collect it automatically by SEPA Lastschrift instead of waiting for transfers.
- The shopper signs a SEPA Core mandate at checkout.
- You ship the order.
- The debit runs on day 30 after a pre-notification.
- Returned debits trigger reminders with a payment link.
What you take on
You carry the payment risk — the same risk you'd carry with a plain invoice. In return you keep the customer relationship and stop paying a percentage of every order to a third party. Good risk rules and automatic dunning keep the risk manageable.
Your next steps
- Ask a German lawyer to confirm the exclusion fits your option as implemented in German law.
- Apply for a Gläubiger-Identifikationsnummer with the Deutsche Bundesbank.
- Open a GoCardless account and connect it to Kalplex.
- Start with returning customers, then widen your rules.