CCD2 One Month Out: Where Each Country Stands and What Has Changed

October 15, 2026 at 07:00 AM

On 20 November 2026, the revised Consumer Credit Directive, CCD2, starts to apply in the markets where it has been implemented. That is five weeks from today. A month ago we published a country-by-country overview. Since then the picture has moved in one important place and stood still in most others. This update sets out where each market stands, what our checkout data says about how much each one depends on credit, and what to check this week.

What has moved since September

Very little has changed in the law itself. Sweden, Denmark, Finland, Germany and Austria have passed their implementing rules, and all five apply from the same date. The change is in the market. Sweden's July deadline for standalone consumer credit institutions already removed a number of lenders, and the approval of the providers that remain is now the thing to watch. The Netherlands is the one market where the timetable is still open. Its implementing bill has been in parliament since April and has not been voted on.

Country by country

How much credit each checkout carries

Credit is not the same size everywhere. In Sweden, buy now pay later and invoice carried 53% of completed consumer checkouts from January to September 2026. In Denmark the share is 4%. In the Netherlands it was about 22% and in Germany about 21% over the autumn of 2025, the most recent full baseline we have for those two markets.

That spread is the main reason one plan does not fit all of them. Sweden is the market where the new rules touch the largest part of the checkout. Denmark applies the same directive on the same day, but credit is a small share of its checkouts. The Netherlands is the awkward one. Among the markets in our data, it carries the largest credit share after Sweden, and it is the market where the rules are least settled.

A checkout that sells into Sweden and the Netherlands on the same site runs two different credit regimes behind the same payment button, and only one of them changes in the week before Black Friday. That is a configuration question, not a reason to remove credit from the Dutch checkout. Keep the method, but set the provider list, the disclosure and the consent flow per market, and be ready to switch them on different dates.

Three things to check this week

1. Ask every credit provider in your checkout for its written status with the relevant supervisor, and the date its checkout flow will meet the new assessment and information rules. "We are working on it" is not enough at five weeks out.
2. 2. Set the payment list per country rather than globally. Sweden, Denmark, Finland, Germany and Austria need the compliant flow from 20 November. The Netherlands needs a plan for either outcome.
3. 3. Decide what a declined shopper sees. More consumers will be assessed under the new rules, and the fallback has to be ready before the sale starts, not after the first decline.

We will update this post when the Dutch bill moves

We will update this post when the Dutch bill is voted on, and when any of the five markets publishes its provider list or supervisory guidance. The earlier posts still hold. The country-by-country overview has the full legal detail, our checkout data from September has the Swedish numbers, the Denmark post covers the Danish approach, and the Black Friday checklist has the week-by-week plan.

Methodology note: Credit share is the share of completed Briqpay consumer (B2C) checkouts paid by buy now pay later or invoice. Sweden covers January to September 2026, Denmark February to September 2026, and the Netherlands and Germany the baseline from 1 October to 9 November 2025. Legislative status is as of 15 October 2026, based on official sources and the posts linked above. It is not legal advice. We do not name individual providers.