Why BNPL grew faster than regulators expected
BNPL's core innovation wasn't the idea of instalment credit — that's centuries old — it was moving the credit decision to the point of sale and making it instant. A shopper picks BNPL at checkout, the provider runs a soft credit check in the background, and the purchase is approved before the page finishes loading. That speed, combined with zero-interest short-term plans that don't feel like debt, is why BNPL scaled to tens of billions of euros in transaction volume before most European regulators had a specific rulebook for it.
Regulation has now caught up
That gap closes on 20 November 2026, when the EU's revised Consumer Credit Directive (CCD2) starts applying. It brings BNPL explicitly into the scope of consumer credit law for the first time — mandatory affordability checks, APR and fee disclosure, and the same creditworthiness-assessment obligations that apply to a personal loan. Providers that treated BNPL as a payments product rather than a credit product now have to build the compliance infrastructure of a lender, and several already have.
SME BNPL is a smaller, separate market
Consumer BNPL gets most of the attention, but SME-focused BNPL and checkout financing for business purchasing is a distinct product: a business buying inventory or equipment on trade credit, rather than a consumer buying a jacket in three instalments. The underwriting is different — it looks at business cash flow and trading history rather than a consumer's personal credit profile — and it competes more directly with traditional trade credit and invoice financing than with consumer instalment apps.




