🎧Traditional invoicing faces regulation? In this episode of Alles Legal – Fintech-Recht kompakt, Annerton lawyer Florian Lörsch explains how the new Consumer Credit Directive (CCD2) introduces an entirely new set of rules for Buy Now, Pay Later and similar models. Tune in now!
New Rules for Invoicing & BNPL
In episode #115 of the podcast Alles Legal – Fintech-Recht kompakt, hosted by Dana Wondra (Payment & Banking), Florian Lörsch, lawyer at Annerton, discusses the practical implications of the revised Consumer Credit Directive (CCD2) for merchants and providers of Buy Now, Pay Later (BNPL) products.
What does CCD2 regulate – and why does this now include traditional invoicing?
The EU’s new Consumer Credit Directive significantly tightens the regulatory framework for BNPL products. From now on, even traditional invoicing falls under consumer credit law – bringing extensive information and verification obligations. Depending on their size and sales channels, merchants must meet different requirements. This directly impacts established checkout processes.
Creditworthiness Assessment: Practical or Bureaucratic?
Another key topic is creditworthiness assessment: The draft directive proposes graduated requirements depending on the amount and duration of the credit. However, how this will be implemented remains unclear – as does the regulatory interpretation in practice.
Registration Obligations & AML Risks
Another new aspect: merchants who offer BNPL products themselves must register or obtain a licence under Section 34k of the German Trade Regulation Act (GewO). Platform providers must also increase monitoring of their merchant structures. Additionally, there is potential for new anti-money laundering obligations if CCD2 is interpreted in conjunction with the EU’s AML Regulation.
Conclusion
The new regulation does not mark a radical shift – but it introduces numerous details that providers and merchants now need to be aware of and implement.
About this podcast
Alles Legal – Fintech Recht Kompakt delivers sharp, weekly insights into legal and compliance matters in the world of banking. (in German only)
This podcast is a collaboration between Payment & Banking and PayTechLaw.
Each Wednesday, we unpack the legal developments shaping the financial world – clearly, concisely, and without the legal jargon.
Since 2021, PayTechLaw authors and Annerton attorneys have brought depth and clarity to complex topics.
Whether it’s PSD3, DORA, or FiDA – we provide the legal context you need.
In 20 minutes. No detours.
