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Co-founder, Chief Executive Officer
September 11, 2026 at 07:00 AM
Our last update on CCD2 covered the finished Swedish law, Konsumentkreditlag (2026:1011), and the licensing regime it puts in place ahead of November 20, 2026. Since then, a closely related reform that we flagged only briefly has actually played out, and it's the closest thing to a dress rehearsal for CCD2 enforcement that merchants are going to get before the real deadline arrives.
Under a 2025 amendment to the Banking and Financing Business Act, standalone consumer credit institutions, companies that only grant or broker consumer credit and hold nothing else, lost the right to operate outside full banking or credit-market-company supervision. They were given a one-year transition window that expired on July 31, 2026. Roughly 50 institutions were affected. According to Realtid's reporting and a press release from Brixo, one of the companies now itself licensed as a credit market company, seventeen of them filed applications with Finansinspektionen since the requirement took effect, more than double the five to ten that Brixo's own market analysis had predicted back in March. Of those seventeen applicants, only Sambla Group had secured approval by the deadline, confirmed for June 8, 2026, with CEO Hans Skruvfors calling it "an important step for both our customers and our business." More than a dozen other applications, including from loan brokers like Lendo and Zmarta, were still sitting in FI's queue as the deadline passed. Brixo's own release adds useful historical context: of roughly 100 banking and financing license applications FI has processed since 2010, about a third ended in rejection or withdrawal, so a pending application is no guarantee of the outcome. The clear majority of the roughly 50 affected institutions simply exited the regulated market instead of applying at all.
This matters for CCD2 specifically because it's the same regulator, the same tightened appetite, and largely the same population of smaller credit and BNPL-adjacent providers that will be judged against the new konsumentkreditlagen's own licensing bar over the next twelve months. Anders Dölling at FI's consumer credit unit told us back in February that his team was reaching out to the roughly 50 remaining institutions about the stricter rules. We now know what happened when that conversation turned into an actual deadline: most of the market chose to leave instead of clearing the bar. If a merchant's checkout depends on a smaller invoice or installment provider that hasn't said anything public about its FI licensing status, this is the moment to ask, not November.
Zoom out from Sweden and the picture gets less reassuring, not more.
CCD2's transposition deadline for member states was November 20, 2025. That deadline has now passed everywhere in the EU, and according to Eurofinas, the European trade association for consumer credit providers, only around a third of member states had adopted or substantially finished their national legislation as of mid-2026. The European Commission has already opened the first infringement proceedings against member states that missed the transposition deadline, and Eurofinas is blunt about what that means in practice for lenders operating across borders: "insufficient legal certainty and limited time to implement significant operational changes," with some markets forcing providers to build compliance programs "without knowing the final rules." The directive itself hands member states discretion in more than twenty separate areas, from the exact SEKKI-style disclosure format to how national exemptions are drawn, so even a fully transposed CCD2 doesn't mean one consistent rulebook.
Sweden, by contrast, has a finished statute, a named regulator, a confirmed supervisory split, and a live case study in enforcement behavior three months before the deadline. That's a genuinely unusual position to be in. A merchant selling only into Sweden gets more clarity than most of its European counterparts. A merchant selling across the Nordics and wider EU is instead looking at one market that is fully specified and several others that are still catching up, which is exactly the kind of fragmentation a single checkout can't quietly absorb without some kind of per-market configuration layer underneath it.
Our last post quoted Klarna's largely supportive public position on CCD2. It's worth balancing that with the industry voice that has been more openly critical of how the rules are landing in practice.
Ehandel.se reported that Finansinspektionen's guidance requires a full credit assessment, income, expenses, and existing debt, for every digital credit purchase, regardless of the amount or whether it's interest-free. Roslana Cederhage, General Secretary of the Swedish fintech trade body Swefintech, argued this treats a small interest-free invoice purchase the same as a much larger consumer loan, and warned it will be genuinely difficult to gather that information given that Sweden still has no national debt register merchants or lenders can check against. Her sharpest line was aimed at who gets shut out first: "Man gör det väldigt svårt för många målgrupper, inte minst för de som har en låg pension," roughly, this makes things very difficult for a lot of groups, not least people living on a small pension. Her broader point is that stricter assessment isn't free: it will decline more low-income and older shoppers, not just the over-extended younger BNPL users the law is most often framed around.
That's a useful corrective to reading CCD2 purely as a consumer-protection win with no tradeoffs. It's also a preview of the kind of decline pattern merchants should expect to actually see in their own data after November 20, and it's a different shopper segment than the one most checkout teams are currently planning for.
Beyond the disclosure and dark-pattern rules we covered last time, three specific consumer protections are worth calling out because they change operational behavior, not just checkout copy.
The right of withdrawal doesn't start counting down the moment a credit agreement is signed. It starts once the consumer has actually received the required information about that right. If your disclosure flow buries or delays that information, you are functionally extending your own cooling-off window without realizing it, which has real implications for how long a credit-funded order should be treated as reversible on the merchant side.
Payment difficulty handling is no longer just a courtesy. Credit and BNPL providers are required to offer alternatives, a reduced interest rate, a deferred schedule, before escalating to debt collection. For merchants who rely on a provider's collections process as part of their own customer experience, that's a meaningful change in what a "failed payment" conversation is allowed to look like before it turns into a collections case.
And on design specifically, it's not just our reading. Svea Bank's own guidance to merchants lands on the same three audit questions we'd suggest asking your own checkout team this quarter: are the buttons and alternatives to a credit option equally visible, is declining credit as simple as accepting it, and are there more steps required to cancel than to complete the purchase. Their framing is worth quoting directly: "Kunden ska kunna fatta ett medvetet val. Design och kommunikation får inte styra valet," the customer has to be able to make a conscious choice, and design and communication aren't allowed to steer that choice. When two competing payments providers are giving merchants the same three-question checklist, that's a strong signal it's the actual bar regulators will apply, not a conservative internal guess.
Here's the detail that hasn't been part of the CCD2 conversation yet, and it should be.
November 20, 2026 falls on a Friday. Black Friday in 2026 falls exactly one week later, on November 27. That means the very first full trading week under CCD2's new rules in Sweden is also the single highest-traffic, highest-promotion week of the Swedish e-commerce calendar, immediately followed by Cyber Monday and the run-up to Christmas.
Black Friday campaigns lean hard on installment and "buy now, pay later" messaging precisely because it lowers the perceived cost of a larger purchase, which is exactly the category of messaging CCD2's dark-pattern and equal-prominence rules are built to constrain. There is no quiet week between "the rules are technically in force" and "the busiest checkout traffic of the year arrives." Any bug in a new consent flow, any mismatch between a credit option's visual weight and a card option's, any SEKKI form that renders badly on the mobile traffic spike Black Friday always brings, gets discovered in public, at volume, during the week it's most expensive to discover it.
That argues for a different testing posture than most merchants would default to. A soft launch of new checkout logic in early November, well before Black Friday traffic arrives, isn't just good compliance practice, it's the only way to find out whether your consent flow, your SEKKI rendering, and your decline-handling actually hold up before the highest-stakes week of the year puts them under real load.
Everything above reinforces the same conclusion we reached in our first update, but with sharper evidence behind it now that providers are actually disappearing from the market instead of hypothetically at risk of it.
If seventeen out of roughly fifty licensed institutions applied for continued authorization and only a handful cleared the bar in time, the odds that every BNPL or invoice provider plugged into a given merchant's checkout sails through its own CCD2-driven licensing requirement without incident are not great. A checkout built around a single credit provider is now a checkout with a single point of regulatory failure, and Black Friday week is the worst possible time to discover that failure live.
A payment orchestration layer that already integrates multiple credit, BNPL, and card options changes what happens when one partner's status changes: checkout logic can route around a delayed or lapsed license instead of a merchant losing installment payments in that market entirely. The same layer is also where the equal-prominence and no-dark-pattern rules are easiest to enforce consistently, since they're managed once, centrally, instead of separately by whichever team last touched a given payment integration. And with more declines coming from stricter, verified creditworthiness checks, in Sweden and, unevenly, across the rest of the EU, what a shopper sees in the seconds after a decline matters more this November than it ever has. Our own analysis of retry behavior across more than 31,500 checkout attempts found that when a BNPL attempt failed, 41% of shoppers completed with a different payment method within two minutes, when that alternative was actually offered.
Confirm the licensing and CCD2-readiness status of every credit and BNPL provider live in your checkout now, not in November, and ask directly whether they were among the majority or the minority in July's shakeout. Schedule your new consent-flow and SEKKI-rendering changes to go live in early November so they've survived at least two weeks of real traffic before Black Friday arrives. Rehearse what a shopper actually sees in the moment a credit check fails, since that moment is about to happen more often and to a wider range of shoppers than your current checkout analytics assume. And if you're selling into more than one EU market, don't assume the rules you've mapped for Sweden apply cleanly anywhere else this year, since most of the rest of Europe is still working from an unfinished rulebook.
The Swedish market just showed everyone what happens when a hard regulatory deadline meets a segment of providers that assumed they had more time. November 20 is the same test, run on a larger and more commercially visible part of the payments stack, one week before the industry's busiest weekend of the year.
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