What is BNPL ?
BNPL (Buy Now Pay Later) is a payment facility that allows you to pay for a purchase by spreading the payment over several installments.
Highly appreciated by consumers, this type of installment payment is very popular for its ease of access and its ability to facilitate online purchasing.
Currently, only installment payments of less than 90 days are considered BNPL. From November 20, 2026, any payment in installments, regardless of duration or amount, will be considered consumer credit.
What is consumer credit ?
Consumer credit is regulated by the Consumer Code. It is granted by a financial institution, directly or through a merchant, to an individual for non-professional needs.
Article L312-1: The provisions of this chapter apply to any credit operation mentioned in point 6° of Article L. 311-1, whether it is concluded for consideration or free of charge and, where applicable, to its guarantee, provided that the total amount of the credit is equal to or greater than 200 euros and less than or equal to 75,000 euros.
Repayment is made in monthly installments comprising the principal borrowed and interest. The interest represents the total cost of the loan to the borrower and may include additional fees such as application fees, insurance, or guarantees.
The applied rate, called the APR (Annual Percentage Rate), varies depending on the lending institution but cannot exceed the legal maximum interest rate. The total cost of the loan depends on both the interest rate granted and the chosen repayment period.
New BNPL rules with DCC2
As of November 20, 2026, the transposition of European Directive (EU) 2023/2225 (DCC2) broadens the scope of consumer credit. From this date, any payment made in installments, including interest-free installment payments with a term of less than 3 months, will be considered consumer credit and subject to the associated legal obligations.
Expanded scope
The following will be considered consumer credit :
- All guaranteed installment payments (BNPL), even without interest, will fall within the scope of consumer credit, without exclusion based solely on duration or absence of fees.
- Short-term loans (less than three months), which were partially excluded until now, will now be subject to lighter obligations but included in the general framework.
Enhanced pre-contractual obligations
- Any credit offer, including BNPL, must provide clear, fair and non-misleading information before subscription, with a standardized document given to the consumer.
- Analyzing the customer’s creditworthiness becomes systematic, even for small amounts.
Consumer protection
- Transparency rules apply to all loans, including those with no apparent fees. The directive specifies that all information must remain clear and understandable, including on mobile devices or online, to ensure a smooth and transparent customer experience.
- Certain obligations, such as the right of withdrawal and information on the total cost of credit, must be respected according to national regulations.
The directive maintains very targeted specific cases of exclusion (example: very short deferred payments without charge for certain SMEs), but these exceptions are strict and limited.
The CentralPay installment payment offer
CentralPay combines payment flexibility for the customer with secure cash receipts for the merchant. Depending on your business, several options are available: guaranteed installment payment (BNPL) or standard installment payment.
Guaranteed installment payment (BNPL): CentralPay relies on approved credit partners, such as Oney, Alma, Floa, and Klarna, to offer these services. You get paid immediately, while the customer repays according to the agreed schedule. Commissions apply, but the solution offers maximum security for payments, regardless of the order value, in both B2C and B2B transactions.
→ Will be considered as consumer credit from November 2026.
Standard split payment : CentralPay allows you to divide an amount and stagger the payment as you wish (for example, 30% upon ordering and the remainder over 3 months). You can also schedule the sending of payment links and customer notifications for fully automated management.
