FFinTech
Bin ich Kreditgeber im Sinne der Verbraucherkreditrichtlinie? Am I a creditor within the meaning of the Consumer Credit Directive?
Read More
  • 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.
Read More
PPayment
Am I a credit intermediary under section 34k GewO? Bin ich Darlehensvermittler nach § 34k GewO?
Read More
  • 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.
Read More
PPodcast
Kreditwürdigkeitsprüfung unter der CCD2: Was sich jetzt konkret ändert | ALLES LEGAL #135 Creditworthiness Assessments under CCD2: What Is Changing in Practice | ALLES LEGAL #135
Read More
  • 2 minute read

Creditworthiness Assessments under CCD2: What Is Changing in Practice | ALLES LEGAL #135

The new Consumer Credit Directive CCD2 significantly tightens the requirements for creditworthiness assessments. In future, credit may only be granted where repayment in accordance with the contract appears likely. Discussing what this means for banks, fintechs and BNPL providers, how scoring and automated decisions will be affected and why companies should now take a close look at their processes.
Read More
PPayment
Buy Now Pay Later und der neue Anwendungsbereich des Verbraucherdarlehensrechts The implementation deadline for CCD2 is approaching – and consumer credit law will soon apply to BNPL models
Read More
  • 9 minute read

The implementation deadline for CCD2 is approaching – and consumer credit law will soon apply to BNPL models

Buy Now, Pay Later (BNPL) has evolved from a simple payment method into a major financing tool in e-commerce—and is now under regulatory scrutiny. The Second Consumer Credit Directive and its implementation in Germany expand the scope of consumer credit law significantly. This article explains which BNPL models will fall under consumer credit rules in the future and where lawmakers draw the line.
Read More