Overview
- From November 20, 2025, even interest‑free purchases under €200 and short‑term plans will count as consumer credit, requiring mandatory creditworthiness assessments.
- Lenders must provide standardized pre‑contract information, comply with caps on late fees and interest, and honor a 14‑day withdrawal that voids the installment credit.
- Checkout processes will ask for more data and may slow to minutes rather than seconds, and customers with multiple active BNPL agreements could be refused.
- The Bundestag is currently transposing EU 2023/2225 into national law, with a requirement for “proportionate” checks that leaves scope for interpretation.
- Consumer advocates at VZBV seek stricter vetting and a signature to prevent “debt by click,” while PayPal deems thorough checks disproportionate and Klarna favors alternative‑data reviews, citing counseling cases of rapid over‑indebtedness among young users.