What is CCD2 and when does it come into effect?

CCD2 – the Consumer Credit Directive 2 – is a European regulation introducing new compliance requirements for BNPL providers across EU markets including Germany. It covers updated payment flows, Strong Customer Authentication, revised consumer credit disclosures, advertising restrictions, late payment cost caps, and mandatory age verification. The regulation is already in effect, with requirements being phased in across markets.

What does CCD2 mean for fashion retailers?

For fashion merchants, CCD2 creates a divergence at checkout. Providers who aren’t exempt from the new requirements are adding verification steps – introducing friction at a point where conversion is already fragile. Beyond the compliance question, CCD2 creates a natural moment to ask whether your BNPL provider’s business model is genuinely working for you; or quietly working against you.

What should retailers consider when reviewing their BNPL provider after CCD2?

Compliance is the minimum expectation, not the measure of a good partner. The questions worth asking go beyond the regulation: Does your provider redirect your customers to their own marketplace or shopping destination after checkout? Who owns the data generated at your checkout, and what is it being used for? And when something goes wrong – a return, a dispute, a payment query – does your provider handle it cleanly, or does the complexity come back to your team? CCD2 has created the moment to ask; these are the questions worth asking in it.

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CCD2 is sorted. Now ask the harder questions

A new regulation has landed in Germany. For most BNPL providers, it means new compliance steps, additional verification, and changes to the checkout experience. For merchants using Riverty’s 14-day invoice, the situation is currently simpler – this product is temporarily exempt from these requirements, so the checkout experience stays as it is; no additional friction, no new steps for your customers. For merchants in Germany, it’s a concrete advantage at a moment when competitors are adding steps.

Jun 8, 2026 3 minutes

A simpler checkout is the door-opener. CCD2 has put every merchant’s BNPL setup under a microscope. And once you’re looking, there’s a more important question to ask – one your current provider perhaps would rather you didn’t.

Compliance is a floor, not a ceiling

Meeting regulatory requirements means your checkout is legal – it doesn’t tell you whether your BNPL provider is actually working for your business, or quietly working against it.

Growth is good. Until the operation behind it stops scaling.

Fashion ecommerce is built on returns, seasonal peaks, and customers who know exactly what they expect. s.Oliver had all of that – plus a loyal base with long memories and high standards.

For years, they managed invoice payments in-house. It worked, until the business grew large enough that the operational cost became hard to ignore: a risk process that needed around 10 people to run, limited visibility across teams, and complexity that was starting to slow down plans for international expansion. No single breaking point. Just a gradual realisation that handling everything yourself has a ceiling. See how s.Oliver turned in-house complexity into a reliable partnership.

The minimum expectation is exactly that: minimum

A BNPL partner that keeps your checkout compliant is doing what you’re paying them for. The harder question is whether your provider’s business model is aligned with yours, or structured around competing with it.

A partner whose only business is serving merchants – not building a consumer marketplace, not monetising purchase data, nor redirecting customers to a competing destination – looks different, and over time, it compounds differently.

Compliance sorts the floor. Now you know what to build on it.