CCD2: Buy Now Pay Later (BNPL) Becomes Consumer Credit — What Changes for Your WooCommerce Store

Alma, Klarna, Oney, PayPal Pay in X: if your WooCommerce store offers any of these installment payment options, you're affected by the Consumer Credit Directive 2 (CCD2, EU 2023/2225), which takes effect on November 20, 2026. The directive brings Buy Now, Pay Later (BNPL) into the scope of consumer credit regulation — even when the advertised APR is 0%. Your payment provider absorbs most of the technical complexity, but three specific obligations remain on the merchant. This article breaks down who handles what, the new mandatory legal disclosures on your advertising, and how to check your compliance before the deadline.

What is CCD2 and why your installment payments are affected

The Consumer Credit Directive 2 (EU 2023/2225) modernizes and broadens the scope of consumer credit regulation across the European Union. Its transposition into French law takes effect on November 20, 2026. In practice, it brings installment payments — 2, 3, 4 installments and beyond, commonly known as BNPL (Buy Now, Pay Later) — into the scope of consumer credit, regardless of the displayed APR, including 0%. Until now, fee-free installment payments largely escaped this legal framework; that will no longer be the case.

If your WooCommerce store offers Alma, Klarna, Oney, PayPal Pay in X, Floa, or any other installment payment provider, that payment method now changes legal status — with direct consequences for your advertising disclosures and your store configuration.

Who does what: obligations split between provider and merchant

What falls on the BNPL provider

Most of the credit mechanics are handled by the provider (Alma, Klarna, Oney, PayPal, etc.):

• Displaying the APR directly in the checkout flow.
• Adding a credit agreement signature step.
• Providing the SECCI (Standard European Consumer Credit Information sheet).
• Managing the credit-specific right of withdrawal (14 days, notified by email around 3 days after purchase).

What remains your responsibility as a merchant

Three specific obligations cannot be delegated to the provider:

1. Activate cart and delivery data sharing with your BNPL provider. This is an explicit requirement of the French transposition (article R312-10): the signed credit agreement must reference the actual good or service purchased, which requires the provider to receive cart contents plus shipment status and details.
2. Update every piece of advertising that mentions installment payments — website, social media, newsletters, SMS, video, radio — with the new mandatory legal disclosures (detailed below).
3. Remove any outdated ORIAS/IOBSP registration mention if one still appears on your site: it's no longer required to advertise these financing options, provided your ads are validated by the lender.

The new mandatory legal disclosures on your advertising

The French transposition sets a graduated disclosure requirement depending on what your ad highlights:

• Mentioning the payment method alone (e.g. "Pay with Alma") with no reference to installments: no legal disclosure required.
• Mentioning installment payment without mentioning cost (e.g. "Pay in installments"): a 2-element legal block — a warning sentence displayed in a font size larger than standard legal notices: "Warning! A credit costs money and must be repaid", plus a legal statement identifying the ACPR-approved lender.
• Mentioning installments with a cost claim (e.g. "fee-free"): a 3-element block — the two above, plus a representative numerical example of the largest advertised payment plan (amount, down payment, installment amounts, cost of credit, APR).

Where these disclosures must appear depends on the format:

• Web banner / newsletter → footer.
• Social media post → warning directly on the image, remaining text in the description.
• Story → link to Terms & Conditions.
• SMS → link to Terms & Conditions.
• Video → bottom of the end screen.
• Radio → disclosures at the end of the spot, read at 1.5x speed.

Quick checklist: is your store affected?

• Data sharing: is cart/delivery data sharing activated with your BNPL provider?
• Legal disclosures: are they present on your product pages, banners, T&Cs, and ads mentioning installments?
• ORIAS: is an outdated ORIAS/IOBSP registration mention still lingering somewhere on your site?
• Consistency: does what's advertised on your homepage match what's actually configured and documented in your T&Cs?
• Widget: is your BNPL provider's plugin/widget up to date?

If you're unsure about any of these, your store probably isn't ready for November 20, 2026 yet.

How to become compliant before November 20, 2026

1. Contact your provider (Alma, Klarna, Oney, PayPal…) to confirm its rollout timeline for cart/delivery data sharing.
2. Audit every advertising surface mentioning installment payments: website, social media, newsletters, SMS, video.
3. Update your Terms & Conditions and legal notices to reflect the new consumer credit qualification.
4. Remove any outdated ORIAS mention still present.
5. Run a full re-check a few weeks before the November 20, 2026 deadline.

What are the risks of non-compliance?

French consumer protection authority DGCCRF monitors misleading commercial practices around credit advertising, and the ACPR oversees advertising compliance for financing offered by approved lenders. But the most immediate risk is often commercial before it's regulatory: a BNPL provider can suspend the option on your store if cart and delivery data sharing isn't activated or if your legal disclosures aren't compliant — with a direct impact on your conversion rate, since installment payment is often one of the most-used payment methods at checkout.