Click “pay later” at an online checkout and you are often taking out a loan – and from late November the law will say so far more plainly. On 20 November 2026 most of Germany’s new consumer credit rules take effect (as of 24 October).
The law transposes EU Directive 2023/2225 and was promulgated in the Federal Law Gazette on 18 May 2026. The Bundestag passed it in April; the EU deadline for transposition had already expired in November 2025. For shoppers the key point is that much of what felt harmless will legally count as credit.
What counts as credit from now on
According to the federal government (19 May), consumer-protection rules will now also cover small loans up to €200, interest-free and fee-free credit, loans with a term of up to three months, and “buy now, pay later” models such as those offered by Klarna or PayPal. The Bundestag exempted debit cards with deferred payment. Ordinary purchase on invoice generally stays outside the rules, according to the consumer advice group Bundesverbraucherhilfe, as do credit cards with interest-free monthly billing.
Where the line falls depends on how an offer is built: if a payment provider finances the purchase, the delay costs money or the deadline is longer than on a normal invoice, it is likely to be credit. That is Bundesverbraucherhilfe’s reading; individual cases may be judged differently.
The new rights include:
- Lenders must check before signing whether you can repay. Social-media and health data may not be used for this, says Bundesverbraucherhilfe.
- If the decision rests on automated processing, you can demand human review, according to the government.
- You receive standardised information up front – even free credit comes with a one-page fact sheet.
- Withdrawal: 14 days. If the information given was faulty, the right ends at the latest 12 months and 14 days after signing; the “eternal right of withdrawal” is abolished.
- For an ordinary consumer loan, text form such as an email will be enough.
Contracts concluded before 20 November generally remain under the old law.
What changes day to day – and what is still open
In practice it is worth checking the total cost before you click, and whether the information and withdrawal instructions actually reach you. Biallo points to credit-bureau Schufa: pure enquiries about terms do not affect your score, genuine credit applications can lower it slightly for a short time, and a missed payment can be reported as default – a problem later for a flat, a mobile contract or a loan. If money gets tight, talk to the provider early; free debt counselling is offered by Caritas, Diakonie and the consumer advice centres, among others.
How providers will implement the new creditworthiness check is still open. Biallo says it is not yet settled; existing market participants get transition periods of up to twelve months, according to KPMG. Our assessment, with no guarantee: instant instalment offers at the till are likely to be granted more cautiously, and people who have lived in Germany only a short time and have a thin Schufa record may be declined more often. That is an editorial forecast, not a statement by the sources.
A note on accuracy: we rely partly on summaries by consumer portals. The binding text is in the Federal Law Gazette, 2026 I No. 139.
Sources: Bundesregierung, Bundesverbraucherhilfe, Biallo, KPMG
