CCD2 from November 2026: What Germany’s new consumer credit rules mean for instalment payments in online businesses

If you sell online courses, coaching, digital products or services and let customers pay in instalments, it is time to look closely at your payment arrangements. From 20 November 2026, Germany’s new consumer credit rules will apply. Interest-free instalments and small amounts may also be subject to stricter requirements. What does this mean for self-employed people, online retailers and digital businesses? And how can you continue to offer flexible payment options?

Instalment payments have long been part of the business model for many online companies.

An online course costs €1,200? Instead of paying the entire amount immediately, a customer might agree to six monthly payments of €200.

Similar arrangements are common for coaching, consultancy, memberships and digital products.

Payment plans that businesses and customers have often agreed directly and with little complexity may, however, face considerably stricter rules from 20 November 2026.

The reason is the new EU Consumer Credit Directive, commonly called CCD2, and its implementation in Germany.

Particular attention is needed where a provider has already supplied the full service while the customer continues to pay for it over several months.

What is the new EU Consumer Credit Directive, CCD2?

Directive (EU) 2023/2225 was adopted in October 2023. Its purpose is to improve consumer protection in credit agreements throughout the European Union.

One reason for the reform is the growing use of digital financing options.

Examples include:

• Instalment purchases in online shops
• Buy now, pay later (BNPL) offers
• Interest-free financing
• Short-term small loans
• Deferred payments and certain agreements to pay in instalments

Some of these arrangements have not previously been subject to the full set of special consumer credit requirements.

That is changing.

In particular, the new version of section 506(1) of Germany’s Civil Code (BGB) extends the corresponding application of general consumer loan provisions to financial assistance that is provided without a charge. A zero-interest offer is therefore not, by itself, an exemption.

Germany transposed the directive into national law through legislation dated 12 May 2026, promulgated on 18 May 2026 in the Federal Law Gazette, Part I, No. 139. The main new consumer credit provisions apply from 20 November 2026.

This brings financing models previously treated as straightforward payment options into sharper focus.

Why are providers of digital products particularly affected?

Digital products and services often differ from physical goods.

While a physical product must be dispatched, an e-book, software package, video course or digital template can be made available immediately after purchase.

A customer might, for example, receive immediate access to an entire online course but pay for it over twelve months.

Economically, the service has already been supplied, while full payment takes place later.

Arrangements like this need particularly careful assessment under the new rules.

Example: An online course paid for in twelve monthly instalments

Suppose you sell a recorded video course for €1,200.

Your customers receive access to all the content immediately after purchasing it.

You offer twelve monthly payments of €100 as a payment option.

You are therefore allowing customers to pay the price over an extended period even though they have already received the agreed service.

An arrangement like this may fall within consumer credit law as a form of financial assistance.

Important: Charging no interest does not automatically create an exemption.

So-called zero-percent financing can also be covered by the new provisions.

Does this mean that all instalment payments will be prohibited?

No.

The new Consumer Credit Directive does not ban instalment payments.

It extends the scope of consumer credit rules and, with it, the requirements for certain financing arrangements.

The contractual payment terms, the timing of performance and the identity of the party providing the financing are decisive.

There are important distinctions to make.

Short payment deferrals without a charge

Not every purchase on invoice automatically becomes regulated consumer credit.

A statutory exemption can apply where a business itself gives its customer additional time to pay without a charge and meets the relevant conditions.

In particular:

• The supplier itself grants the payment deferral.
• No third party provides a loan, deferred payment or other financial assistance.
• There is no interest or other regular charge for the deferral.
• Only limited costs that are lawful under national law may arise if the customer defaults.
• Payment is completed within 50 days after delivery of the goods or performance of the service.

A stricter rule applies to certain larger online providers. This concerns businesses that are not micro, small or medium-sized enterprises under Recommendation 2003/361/EC and provide the relevant information-society services through distance contracts. For them, the payment period must not exceed 14 days, and, in addition to the other conditions, no third party may acquire the loan, deferred payment or other financial assistance.

The exemption is therefore not blanket permission to offer any instalment arrangement.

What about deferring an existing debt later on?

There is also a distinction between agreeing instalments at the time of purchase and subsequently deferring an existing debt.

If a customer cannot pay an existing invoice on time, a deferral granted without a charge may fall within a statutory exemption.

This does not mean that a long-term financing plan intended from the outset can simply be relabelled as a later deferral.

The actual contractual arrangement is what matters.

What additional obligations may businesses face?

Where a payment model falls within the new consumer credit rules, additional requirements arise.

The specific obligations depend, among other things, on whether you act as the creditor yourself or merely arrange financing provided by somebody else.

1. Assess creditworthiness

Before covered credit or the corresponding financial assistance is granted, a thorough creditworthiness assessment may be required.

Its purpose is to assess whether the consumer is likely to be able to meet their payment obligations.

If you have previously offered your own payment plan directly in the checkout, you need to check whether that process will still be sufficient.

2. Provide comprehensive information to customers

Consumers must receive the legally required information before entering into the agreement.

Depending on the financing model, this includes the duration, payment obligations, costs, consequences of late payment and withdrawal rights.

Reduced information requirements may apply to certain small, short-term or interest-free credit agreements.

A brief message such as “Pay in six instalments” is not sufficient on its own for a regulated financing agreement.

3. Adapt contracts and checkout processes

The new rules also affect the form and content of contracts.

General consumer loan agreements in Germany can, in principle, be concluded in text form (Textform) under the new provisions. This German legal concept has specific requirements and should not be treated as a universal international rule about electronic contracts.

There are also particular requirements for an unambiguous declaration of consent.

Preselected options must not cause consumers to enter a financing agreement without realising it.

Online shops and sales platforms may therefore need to revise their checkout processes.

4. Review withdrawal information and documentation

Existing processes for informing customers about withdrawal rights and documenting contracts also need to be reviewed.

Where the required pre-contractual information is provided less than one day before the customer makes their binding declaration, a reminder of the right to withdraw must generally be sent within one to seven days after receipt of that declaration. The precise allocation of duties and the statutory exceptions must also be checked.

Depending on the arrangement, further information and documentation requirements may apply.

Incomplete mandatory information can also have legal consequences.

5. Check authorisation and registration requirements separately

In addition to contractual requirements, public-law obligations may arise.

For credit intermediaries, the new section 34k of Germany’s Trade Regulation Act (GewO) is particularly relevant.

Businesses that themselves grant certain consumer credit or financial assistance also need to consider Germany’s new Sales Financing Supervision Act, the Absatzfinanzierungsaufsichtsgesetz (AbsFinAG).

These are separate regimes with different exemptions. Under section 34k(4), number 3, GewO, an exemption may apply to an SME that carries out the relevant activity solely to finance its own goods or services. The registration exemption in section 4(2), number 1, AbsFinAG requires, among other things, SME status, payment deferrals solely for the supplier’s own goods or services in an ancillary capacity, no interest and only limited lawful default costs. These conditions must be met together; there is no general exemption for every small business offering credit.

An exemption from an authorisation or registration requirement does not automatically remove the contractual consumer protection obligations under the BGB. Applicable transitional provisions must also be considered separately.

Not every business offering instalment payments therefore automatically needs a banking licence or BaFin registration. Whether authorisation or registration is required needs its own assessment.

Which payment models may still be useful?

Many online businesses will still have ways to offer their customers flexible payment terms.

The contractual payment structure should, however, match the actual provision of the goods or services.

Option 1: Payment before the service is supplied

One relatively straightforward approach is to complete payment before making the service available.

Customers could, for example, pay for a workshop over several months in advance.

Access to the workshop would only be provided after the full amount has been paid.

Because this generally does not finance payment after a service has already been supplied, it differs from a typical purchase paid for in instalments after delivery.

Option 2: An ongoing service with regular payments

Regular payments may be appropriate for services provided on an ongoing basis.

An example is a monthly membership under which the customer receives a new entitlement to services each month and pays a monthly fee for it.

This may be economically and legally different from a course that has already been delivered in full and whose price is merely spread over twelve months.

It is not enough, however, simply to rename an existing instalment purchase a “subscription”.

The contract must reflect the service that is actually owed.

Option 3: An invoice with a short payment period

An ordinary invoice with a short payment period and no charge for the deferral may also remain possible.

The statutory conditions for the 50-day exemption, or the special 14-day rule for the relevant larger online providers, are particularly important here.

Option 4: Use a specialist financing provider

Another option is to process instalment payments through a specialist financing provider.

This may include suitable services offered by payment providers or financing partners.

The external provider can then take on important tasks such as assessing creditworthiness and administering the credit.

Before integration, however, check who legally acts as the creditor or credit intermediary and which obligations remain with your business.

Using an external payment provider does not automatically remove every requirement that applies to the seller.

What does CCD2 mean for coaches, agencies and self-employed people?

Providers selling high-priced services and offering their own payment plans should pay particular attention.

Examples include:

• Online coaching and mentoring programmes
• Digital training and video courses
• Consultancy services for private customers
• Memberships with fixed service periods
• Digital product bundles and software offers

It is important to distinguish transactions with consumers from transactions with businesses.

The Consumer Credit Directive generally concerns contracts with consumers.

Purely business-to-business transactions are not automatically covered by these consumer credit rules.

If you sell to both businesses and private individuals, check exactly which payment models you offer to each customer group.

The actual period over which the service is supplied matters too.

An eight-week coaching programme paid for over twelve months may need a different assessment from twelve months of support paid for monthly.

Counting the number of instalments is therefore not enough.

What happens to instalment agreements already in place?

The new rules generally apply to relevant new agreements entered into from 20 November 2026.

Existing credit agreements generally remain subject to the previous law.

Some new duties apply to certain open-ended credit relationships as exceptions to that principle.

Businesses therefore do not automatically have to terminate or replace every instalment agreement already running at the cut-off date.

New offers should nevertheless be reviewed in good time.

Checklist: What to do before 20 November 2026

If you sell digital products or services to consumers, use the remaining time to review your business model.

1. List your payment models: Which products can customers buy on invoice, in instalments or with deferred payment?
2. Check when you perform the contract: When do customers actually receive the agreed service, and when is payment completed?
3. Assess the exemptions: Do statutory exemptions apply, for example to a short payment period without a charge?
4. Contact your payment provider: Ask your shop or payment service provider how it is implementing the CCD2 requirements.
5. Develop alternatives: Consider advance payment, genuine ongoing service arrangements or external financing solutions.
6. Review the checkout and contractual documents: Are payment terms, mandatory information and declarations of consent correctly designed?
7. Obtain a professional assessment: Have individual payment plans legally reviewed before the cut-off date, particularly for high-priced digital offers.

With automated sales processes in particular, it is sensible not to leave changes until immediately before the new rules apply.

Conclusion: Flexible payments remain possible, but the rules are changing

From 20 November 2026, Germany’s implementation of the new EU Consumer Credit Directive brings considerably more financing arrangements within consumer credit law.

These include certain interest-free instalment plans, small loans and buy now, pay later models.

For providers of digital products and services, the key questions are when the service is supplied and how long customers continue to pay afterwards.

If you allow customers to pay over several months for services already provided in full, you should review those payment arrangements carefully.

This does not mean that instalment payments will be prohibited in general.

Short deferrals without a charge, genuine ongoing service models and financing through suitable partners may remain options.

The important point is to design payment terms with both the customer experience and the new statutory requirements in mind.

Flexible payment models should remain attractive to customers while avoiding unnecessary legal risks for the business.

This article provides general information about Germany’s new consumer credit rules and is not individual legal advice. The assessment depends on the specific contract, the period of performance and the businesses involved. The BGB, GewO and AbsFinAG rules and exemptions described here concern Germany. Do not assume that they apply unchanged in Austria, Switzerland, other EU countries or internationally. Other countries implement CCD2 through their own national legislation, and cross-border offers require a separate assessment of the law that applies.