FFinTech
Bin ich Kreditgeber im Sinne der Verbraucherkreditrichtlinie? Am I a creditor within the meaning of the Consumer Credit Directive?
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  • 5 minute read

Am I a creditor within the meaning of the Consumer Credit Directive?

Instalment payments, payment by invoice or “buy now, pay later”: the new rules implementing the Consumer Credit Directive may result in new obligations for merchants from 20 November 2026. One of the key questions is whether the merchant itself qualifies as a creditor within the meaning of the AbsFinAG or cooperates with a bank or BNPL provider. We answer the key questions on registration, creditworthiness assessments and other requirements.
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PPayment
Am I a credit intermediary under section 34k GewO? Bin ich Darlehensvermittler nach § 34k GewO?
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  • 4 minute read

Am I a credit intermediary under section 34k GewO?

From 20 November 2026, new rules will apply to the intermediation of consumer credit in Germany. Retailers will therefore need to determine whether they qualify as credit intermediaries under section 34k GewO and require authorisation. This article explains when BNPL, instalment payments and other financing solutions may constitute regulated credit intermediation.
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FFinTech
PFOF-Verbot
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  • 5 minute read

The PFOF ban comes into force: What the new BaFin supervisory statement means for brokers and neobrokers

Since 1 July 2026, the ban on Payment for Order Flow (“PFOF”) has also been in force for purely domestic business relationships in Germany. On 22 July 2026, BaFin published a supervisory statement on this matter, in which it sets out in concrete terms for the first time which business models it considers to be compliant with the rules - and which are not.
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