Choosing “pay later” at an online checkout has often meant stepping outside German consumer credit law. That changes on 20 November 2026, when the law implementing EU Directive 2023/2225 takes effect. It is dated 12 May 2026 and was published in the Federal Law Gazette on 18 May. Status: 1 November 2026.
The directive dates from 18 October 2023 and replaces the 2008 consumer credit directive. According to the Federal Ministry of Justice, it should have been transposed by 20 November 2025 and must apply from 20 November 2026. Contracts that existed before that day generally stay under the old rules.
What is covered, and what is not
Newly covered are interest-free and short-term credit, loans under €200 and comparable payment deferrals. That includes classic “buy now, pay later”, as offered by services such as Klarna or PayPal; whether a specific product falls under the law depends on how it is structured.
Purchase on invoice stays outside. The ministry’s FAQ states explicitly that this holds even when big online retailers assign the claim to group companies or platform-owned payment providers. Also outside: debit cards with interest-free deferral, including charge cards that collect payments for up to 40 days. Some trade sites headline it differently; the statute and the ministry FAQ are the authority here.
What buyers get
- Creditworthiness check: credit may be granted only if repayment is likely; the depth of the check depends on type, term, amount and risk. If the check is automated, consumers have a right to human review. Social-media data and health data may not be used.
- Withdrawal: 14 days without giving reasons. If the right was explained wrongly, the period ends after 12 months and 14 days at the latest.
- Information: for interest-free credit a clear one-page sheet is enough, and advertising must say that borrowing costs money.
- Contract by email: the written-form requirement goes; text form suffices.
- Forbearance: if someone gets into payment difficulty, the lender must, at the latest before enforcement, offer adjustments such as deferral or a longer term where appropriate.
- Overdraft: a right of withdrawal, a notice period of at least two months, and an offer of 12 equal monthly instalments before enforcement.
In the Bundestag, the CDU/CSU and SPD voted for the law and the opposition against. According to Berliner Zeitung, Justice Minister Stefanie Hubig (SPD) called it an important day for consumer protection, while Ramona Pop of the consumer federation vzbv pointed to the particular over-indebtedness risk of such models. The Greens and the Left criticised gaps in protection, including the relaxed form requirement.
Our assessment, with caution: for small amounts, providers are likely to ask for more information or decline more often, so the instant approval may no longer be a given. How Klarna and others will implement the rules is unclear; Stiftung Warentest says they had not answered its questions. In practice: read the information sheet, note the withdrawal deadline, ask for human review after an automated rejection, and talk early to the provider or a free debt-advice service if payments become hard.
Sources: Federal Law Gazette, Federal Ministry of Justice, Stiftung Warentest, Biallo, Berliner Zeitung
