Starting November 20, 2026, Directive (EU) 2023/2225, commonly called the EU Consumer Credit Directive II or CCD2, will apply to certain consumer-credit arrangements. These rules may affect some payment plans, including certain interest-free installment options.
If you use ThriveCart, you may be wondering what this means for your business and your customers. The good news is that ThriveCart isn’t the lender or payment service provider. Payments are processed through providers such as Stripe and PayPal, while third-party financing products, including Klarna, operate under their own financing arrangements.
Still, some payment plans configured by merchants may fall within the scope of CCD2. That’s why it’s important to understand the basics and review your setup before the directive takes effect.
Key insights:
- CCD2 may apply to some interest-free installment plans, not just traditional loans.
- Genuine subscriptions for ongoing services may generally fall outside CCD2 when the service is delivered throughout the subscription period.
- Merchants are responsible for reviewing their own payment terms and getting appropriate legal advice.
- ThriveCart is continuing to assess the impact of CCD2 and will share updates if our functionality or guidance changes.
What is the EU Consumer Credit Directive?
The EU Consumer Credit Directive is a set of rules designed to protect consumers who use credit or credit-like payment arrangements.
The updated version, known as CCD2, expands the types of arrangements that may be treated as consumer credit. In some cases, this can include interest-free installment plans where a customer receives a product or service before making all of the required payments.
The directive is intended to help consumers:
- Understand the total cost and terms of an arrangement
- Compare different credit products
- Avoid unaffordable borrowing
- Receive clearer information before entering into an agreement
- Get stronger protections when using consumer credit
While the directive applies across the EU, the details of how it’s implemented can vary by country. The exact outcome may depend on the product or service being sold, how and when it’s delivered, the payment terms, and other facts about the arrangement.
CCD2 is an EU directive, which means each member state implements it through national law. The core framework is shared across the EU, but some details may vary by country. Merchants shouldn’t assume that one identical compliance process will apply everywhere.
That’s why there isn’t a single answer for every business or every payment plan.
When does CCD2 apply?
CCD2 applies from November 20, 2026.
This means merchants offering payment arrangements to EU consumers should review their setup before that date, especially if customers receive full access to a product, course, membership, or service before they’ve completed all scheduled payments.
The date doesn’t mean every subscription or installment arrangement will automatically become regulated credit. It means certain arrangements may need to be assessed under the new rules.
Could short deferred-payment plans be excluded from CCD2?
Some short deferred-payment arrangements may fall outside CCD2 if specific conditions are met.
Generally, the exclusion may apply when:
- The merchant or service provider, without a third party offering credit, gives the customer time to pay.
- The purchase price is free of interest and other charges, except for limited late-payment charges allowed by national law.
- The customer completes payment within 50 days of receiving the product or service.
For certain suppliers that aren’t micro, small, or medium-sized enterprises and that offer information society services through distance contracts, the exclusion is narrower. In those cases, payment may need to be completed within 14 days.
These exclusions are specific and shouldn’t be treated as a general safe harbor. A longer split pay plan, a plan involving a third-party finance provider, or a plan where the customer receives a complete product upfront may require a separate CCD2 assessment.
Could split pay arrangements fall under CCD2?
It depends on what you’re selling and how your customers receive it.
A merchant-configured split pay arrangement may be more likely to raise consumer-credit questions when:
- The customer receives the full product or service upfront
- The customer pays over a fixed period
- The customer receives the full benefit before all payments are complete
- The arrangement continues after the product or service has already been delivered
- The payment schedule creates a credit-like arrangement, even without interest
For example, suppose a customer buys a one-time online course and receives immediate access. They then pay for that course in six monthly installments. Depending on the arrangement, applicable national law, and whether an exclusion applies, the payment plan may need to be assessed as consumer credit, even if the customer pays no interest.
This doesn’t mean the arrangement is automatically prohibited. It means the merchant may need to understand whether additional requirements apply.
Do interest-free payment plans count as credit?
They can.
A common misunderstanding is that consumer credit only applies when interest is charged. Under CCD2, some interest-free installment plans may still fall within the scope of the rules.
The key question isn’t only whether interest is charged. It may also depend on factors such as:
- When the customer receives the product or service
- Whether the purchase is a one-time sale or an ongoing service
- How long the customer has to pay
- Whether the customer is paying after receiving the full benefit
- How the arrangement is structured under local law
Because these details matter, merchants should avoid assuming that an interest-free plan is automatically outside CCD2.
Are subscriptions treated differently?
A genuine subscription for an ongoing service may generally fall outside CCD2 when the service is delivered throughout the subscription period. But the word “subscription” doesn’t decide the issue. Merchants should look at what the customer receives, when they receive it, and whether later payments are paying for ongoing service or for a product already delivered.
With a typical subscription, the customer pays for continued access over time. The service is delivered throughout the subscription period, rather than being provided in full at the beginning.
For example, a customer who pays monthly for ongoing access to a software tool, community, or regularly delivered service may have a different type of arrangement from someone who receives a complete course or product upfront and pays for it over several months.
However, calling something a “subscription” doesn’t automatically determine how it will be treated. The real structure of the offer matters.
Merchants should look closely at questions such as:
- Is the service delivered continuously?
- Can the customer stop receiving the service when payments stop?
- Does the customer receive the full value of the product at the start?
- Is the customer paying for ongoing access or paying off a completed purchase?
- Is the arrangement fixed-term, open-ended, or subject to changes?
If customers receive a product or service upfront and continue paying after delivery, the arrangement may need a closer review.
Who is responsible for CCD2 compliance?
ThriveCart provides checkout and billing software. We aren’t the lender, creditor, or payment service provider for merchant-configured payment arrangements.
For merchant-configured split pay arrangements, merchants should assess whether they may be acting as the creditor and whether their payment terms fall within CCD2. If a third party provides the credit, that provider may have creditor obligations, while another party may have separate obligations as a credit intermediary. The specific allocation depends on the arrangement and applicable national law.
Depending on the arrangement and applicable national law, those obligations could include specific customer disclosures, creditworthiness assessments, documentation, registration, or other steps.
As of publication, ThriveCart doesn’t provide creditworthiness assessments or a dedicated CCD2 compliance workflow, including generation of the Standard European Consumer Credit Information form, commonly known as SECCI.
Merchants should review their own offers with qualified local legal counsel before CCD2 takes effect.
How do third-party financing products fit in?
Third-party financing products work differently from merchant-configured payment plans.
Where Klarna provides financing, the arrangement is separate from a merchant-configured split pay plan. Klarna’s role and responsibilities depend on the specific product, country, and contractual structure. Where Klarna is the creditor, it’s responsible for the creditor obligations that apply to that arrangement. Availability depends on factors such as:
- The merchant’s location
- The customer’s location
- Merchant eligibility
- The product or service being sold
- Klarna’s own approval and availability rules
This means merchants using an available third-party financing option shouldn’t assume that the financing arrangement is treated the same way as a split pay plan configured directly by the merchant.
ThrivePay Installments’ availability in the EU, along with the allocation of creditor responsibilities, hasn’t yet been confirmed. We’ll share more information when it becomes available.
What happens to payment plans created before November 20, 2026?
At the EU directive level, credit agreements existing on November 20, 2026, generally remain under the previous framework until they end. Certain provisions still apply to some open-ended credit agreements.
Scheduled payments continuing after November 20, 2026, don’t automatically bring an existing agreement within CCD2. However, a later change, renewal, extension, or replacement may require a separate review under applicable national law.
Merchants should be cautious when making changes to existing plans. Whether a modification changes the treatment of an arrangement depends on the agreement, the nature of the change, and applicable national law.
If you’re unsure whether an existing payment plan is affected, qualified legal counsel can help you understand the specific requirements.
What should ThriveCart merchants do now?
The best next step is to review any payment arrangements offered to EU consumers.
Start by making a list of:
- Split-pay plans
- Fixed-term installment arrangements
- Payment plans for products delivered upfront
- Courses, memberships, or services with immediate full access
- Offers where customers keep access after stopping payment
- Any plans that may be changed, renewed, or extended
- Third-party financing options available at checkout
- Any interest-free, charge-free deferred-payment arrangements that are completed within 50 days, or within 14 days for certain larger online suppliers
Then review how each arrangement works in practice. Consider when customers receive the product or service, how long they have to pay, and what happens if a payment is missed.
You should also speak with qualified legal counsel in the relevant EU country or countries. A legal professional can help determine whether your payment terms fall within CCD2 and whether additional steps are required.
How is ThriveCart approaching CCD2?
We’re continuing to assess the implications of CCD2 for the ThriveCart platform.
Our goal is to give merchants clear, practical information without overstating what our platform can or can’t determine. Because CCD2 may apply differently depending on the product, payment terms, delivery model, and local law, merchants remain responsible for reviewing their own arrangements.
If we make changes to ThriveCart functionality or publish additional guidance, we’ll communicate those updates as appropriate.
We believe the best approach is to be transparent about what we know, clear about what we don’t yet know, and practical about the steps merchants can take now.
What is the main takeaway for merchants?
CCD2 may affect some payment plans offered to EU consumers, including certain interest-free installment arrangements. It won’t necessarily affect every subscription or split pay plan, and it doesn’t mean that every payment plan must be removed.
The most important step is to understand how your own arrangements work. If customers receive a product or service before completing payment, your payment terms may need closer review. That fact alone doesn’t determine whether CCD2 applies, but it may be relevant to the assessment.
Before November 20, 2026, we recommend that you:
- Review all installment and payment-plan offers available to EU consumers.
- Identify whether customers receive the full product or service before completing payment.
- Separate genuine ongoing subscriptions from plans that pay for an upfront purchase.
- Review any changes to existing payment agreements.
- Consult qualified local legal counsel about your specific circumstances.
ThriveCart will continue to assess CCD2 and provide updates about relevant platform changes or guidance.
Important disclaimer: This article is for general informational purposes only and doesn’t constitute legal, tax, or financial advice. ThriveCart doesn’t provide advice on regulatory compliance. Merchants are responsible for ensuring that their products, payment arrangements, and business practices comply with applicable laws and regulations. We recommend consulting qualified independent professional advisers about your specific circumstances.
