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EU Tightens BNPL With Credit Checks for Sub-€200 Purchases as Arrears Rise in Germany

National transposition is due by 20 November 2025, leaving providers roughly a year to implement systems.

Overview

  • An EU consumer-credit directive will require creditworthiness checks for very small loans under €200, bringing BNPL and invoice purchases under stricter oversight.
  • Schufa reports a record share of Germans in strain, with 11% unable to pay rent or loan installments in the past six months since tracking began in 2020.
  • Young adults are most exposed: 26% of 18–25-year-olds paused rent or installment payments, and 44% of BNPL users missed at least one deadline, up from 22% in October 2023.
  • Klarna says it will be fully compliant across its EU markets by November 2026, while PayPal says it already conducts credit checks on its BNPL products.
  • Consumer advocates and major retailers, including the vzbv and Zalando, warn of burdens and potentially superficial checks for very small sums, even as rules also require clearer credit terms.