The CCD2 implementation is now final – but what does this mean for credit cards, BNPL and scoring? Tune in to understand the key changes.
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Germany has finally implemented the EU Consumer Credit Directive (CCD2), with several noteworthy adjustments. In this episode of “Alles Legal”, Dana Wondra speaks with Dr Florian Lörsch about the key differences between the final law and the original draft – and what companies need to do now.
Final CCD2 Implementation: What Applies Now
In this episode, Dana Wondra from Payment & Banking discusses the final CCD2 implementation with Annerton Partner Dr Florian Lörsch.
After a slight delay, the law was adopted on 17 April 2026. Companies now have until 20 November 2026 to fully implement the new requirements. The transition phase is effectively over – focus now shifts to operational implementation.
Clarity for Credit Cards
One major clarification concerns charge cards.
The new law confirms that credit cards with monthly settlement do not fall under strict consumer credit regulation, provided certain conditions are met:
- Issued by a credit or payment institution
- Payment term does not exceed 40 days
- No or only minimal interest
This provides long-awaited legal certainty for many providers.
BNPL: Significant Softening Compared to the Draft
A key change relates to Buy Now, Pay Later models. Under the initial draft, even the assignment of receivables to third parties like Klarna or PayPal would have triggered full regulation. The final law takes a different approach.
Now, regulation only applies if the third party assumes the entire contractual relationship – which is rarely the case in practice.
As a result:
- Many BNPL models remain privileged
- Payment terms of up to 14 days (large companies)
- and 50 days (SMEs)
remain outside CCD2 scope
New Section 37a BDSG: Focus on Scoring
A completely new provision is Section 37a BDSG, addressing scoring practices.
This change is not directly driven by CCD2 but follows recent rulings of the European Court of Justice. Companies should reassess their data protection and scoring processes accordingly.
Overdraft Facilities: Increased Scrutiny
There is also an important clarification regarding overdraft facilities. Consumers will have the right to repay a terminated overdraft in twelve monthly instalments. This leads to stricter requirements for banks: they must assess upfront whether customers can repay from their available disposable income.
In practice, this means:
Income checks alone are no longer sufficient – expenditure must also be considered more systematically.
Conclusion: Time to Act
The final CCD2 implementation brings both clarity and new operational challenges. One thing is certain: there is no more time for delays. Updating IT systems and customer journeys is complex – and November 2026 is closer than it seems.
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.
