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Explainer

Does offering buy now, pay later make my webshop a credit provider?

Usually not. If a separate BNPL company grants the credit, that company needs an AFM licence and your shop is at most an intermediary on the side. Your own interest-free 'pay later' stays outside the rules only if the customer pays within 50 days of delivery, or within 14 days if you are a large online seller.

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Does offering buy now, pay later make my webshop a credit provider?

Usually not. The revised Consumer Credit Directive, Directive (EU) 2023/2225 or CCD2, ends the exemption that kept most buy now, pay later (BNPL) arrangements outside consumer credit law. When a separate BNPL company grants the credit, that company becomes the creditor and needs a licence from the AFM. Your shop presents the option at checkout, which makes it at most a credit intermediary acting on the side.

The answer changes when the credit is yours. A webshop that lets customers pay its own invoice later stays outside the Directive only within tight limits on time, cost and who finances the debt.

Which pay-later models are credit?

How 'pay later' worksCredit under CCD2?What the webshop needs

When do the new rules start?

CCD2 itself says the national rules apply from 20 November 2026 (Article 48). In the Netherlands they come from bill 36924, the Implementatiewet herziene richtlijn consumentenkrediet. The Tweede Kamer passed it on 6 October 2026. The Eerste Kamer has set 27 October 2026 as the date for its first written questions and has not scheduled a vote, and the Act takes effect on a date set by royal decree. A Dutch start on 20 November 2026 is therefore unlikely.

The AFM has accepted licence applications since June 2026, at the applicant's own cost and risk, and a licence cannot take effect before the Act does. Credit cards with deferred debit get six months more after the Act takes effect.

What changes at checkout

Most of the new duties sit with the BNPL company, but customers meet them in your checkout. Before granting any credit, the company must assess creditworthiness thoroughly and may only lend if the customer is likely to repay (Article 18). The Dutch draft implementing decree drops the lower limit for consulting the BKR credit register, so the register is checked before every credit, however small.

Under-18s lose access entirely. The Dutch bill allows credit to a minor only with a guardian's consent and never for deferred payment of goods or services, which is exactly what BNPL is. Advertising may no longer suggest that credit improves someone's financial situation (Article 8(7)(a)).

On 6 October 2026 the Tweede Kamer also adopted motions asking for a mandatory warning sentence at BNPL checkouts and for AFM guidance on which everyday payment and invoicing methods fall under the credit rules. Motions are requests to the government, not law yet.

Questions and answers

We are a small webshop and use a BNPL provider. Do we need an AFM licence?
When does the 50-day period start?
Can customers under 18 still use pay later?
What applies if the Dutch law is late?

Authorities

  • Autoriteit Financiële Markten (AFM)

    The AFM is the Dutch conduct supervisor. It supervises how financial firms behave towards their customers and towards the market: investment firms, asset managers, intermediaries, crypto-asset service providers, audit firms, trading venues and listed issuers. Whether those firms are financially sound is DNB's question, not the AFM's.

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