The EU's revised Consumer Credit Directive (CCD2) closes a loophole that allowed most buy now pay later (BNPL) stores (achteraf betalen winkels) to skip consumer credit regulation. Under the old rules, certain short-term, interest-free instalment credit arrangements, which are what BNPL products look like on paper, were often exempt. However, from 20 November 2026, most BNPL agreements offered to Dutch consumers will fall under new rules concerning responsible lending. Businesses running BNPL at checkout need to know where those rules apply.

Below, we'll cover what's changing in the Netherlands under CCD2, what that means for checkout, and how businesses should consider conversion moving forward.

Key takeaways

• CCD2-related changes are not uniform among all EU member states.

• In the Netherlands, most BNPL products lose their exemption from consumer credit rules once CCD2 takes effect on 20 November 2026.

• Hosted checkout options can reduce the ongoing work of keeping disclosure and withdrawal flows current as BNPL providers adjust to the directive.

What is CCD2?

CCD2 is known in Dutch as the herziene richtlijn consumentenkrediet. It covers most consumer credit arrangements of 100,000 euros or less and includes categories that previously sat outside the directive. Products that avoided credit regulation because they were small, short-term, or interest-free, now largely fall inside it.

Why does CCD2 matter for BNPL?

Under the old directive, BNPL products often skipped credit regulation. The original Consumer Credit Directive let member states exempt certain interest-free, short-term arrangements such as if payment was due within a month. A business could offer instalment payments without prompting the disclosure, creditworthiness, or withdrawal obligations that apply to a personal loan or credit card. In the Netherlands, BNPL has historically been excluded from consumer credit regulation.

CCD2 removes this exemption for short-term, interest-free instalment credit. Going forward, member states will have the option not to apply certain CCD2 requirements to such credits. The Netherlands is moving toward fully regulating BNPL agreements, which means a Dutch business running BNPL at checkout via a service such as Klarna will see a real shift in the legal picture. Creditworthiness checks will become necessary for BNPL arrangements, in addition to other rules relating to advertising and disclosures.

When does BNPL fall under CCD2?

CCD2 was supposed to be implemented into national legislation by 20 November 2025; however, the Netherlands didn't publish its draft implementation until 15 April 2025. The new rules begin on 20 November 2026.

How does CCD2 change online checkout?

Consumer credit providers have a few new and amended requirements regarding responsible lending, age verification, and early identification of consumers with financial difficulties. However, the exact interpretation in the Netherlands is currently evolving. Dutch businesses should consult the Authority for Financial Markets (AFM) for future updates.

How does CCD2 affect conversion at checkout?

A creditworthiness check or other screening adds friction to a flow that BNPL providers designed to be fast. A checkout that used to take two taps might now take four or five. Businesses handling this well are making the new required steps feel like part of the purchase decision rather than an interruption to it. When done right, these measures can double as reassurance, which can positively impact conversion.

Is hosted checkout better for CCD2 compliance?

A hosted checkout page generally gets updated centrally when disclosure requirements or formatting rules change. The business doesn't have to track every adjustment to how a BNPL provider presents its terms, or rebuild its own front-end templates every time a new advertising requirement takes effect.

A custom, self-built checkout gives more control over layout and branding, but it means the business's development team is responsible for more of the compliance burden. They have to build the disclosure screens, wire up the withdrawal notice, and keep the creditworthiness flow current as BNPL providers adjust their application programming interfaces (APIs). This is workable for larger businesses with the engineering capacity to maintain it on an ongoing basis.

Smaller and midsized businesses usually don't have that capacity. Instead, a hosted checkout might be a better option because it shifts the maintenance to the party running the page. This tends to be the more efficient trade-off given how often disclosure requirements can shift during a transposition period such as this one. The business still controls which BNPL options it offers and how they're presented at a high level.

What are the risks of not complying with CCD2?

CCD2 requires each EU member state to set penalties for non-compliance that are effective, proportionate, and dissuasive. The exact figures are set nationally. Dutch businesses follow the AFM to learn how the Netherlands chooses to enforce the law.

How Stripe Checkout can help

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Checkout can help you:

• Increase conversion: Checkout's mobile-optimised design and one-click checkout flow make it simple for customers to input and reuse their payment information.

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