CCD2 readiness guide

On November 20, 2026, the playing field for Swedish e-commerce will change permanently. This date marks the enforcement of Sweden’s updated Consumer Credit Act, implementing the EU’s new Consumer Credit Directive (CCD2). The updated law introduces significantly stricter regulations for invoices, installments and BNPL setups.

For merchants, this is not a dry legal compliance check. It is an executive business challenge that directly impacts checkout economics, net profit margins and liability. 

1. Revenue and conversion impact

Under CCD2, credit assessments must be significantly more comprehensive and conducted strictly in the consumer's financial interest. This applies equally to credit formats that previously enjoyed lighter regulation, like standard 14-day invoices and short-term payment plans.

Stricter credit checks will naturally result in lower credit approval rates. This strikes directly at checkout conversion within credit-based payment methods, while simultaneously eroding secondary revenue streams — such as revenue share agreements, installment conversions, late fee margins and payment reminders.

The volumes involved are massive. Invoices account for roughly 25% of all online checkouts in Sweden — representing an annual payment flow of approximately 40 billion SEK that is about to encounter heavy regulatory friction. For merchants whose profitability relies on kickbacks or subsidized processing fees from credit providers, current operating models are vulnerable.

2. Legal liability and credit intermediation

The second critical issue is corporate liability. A merchant that actively offers, highlights or promotes credit-based payments in the checkout can be classified as a credit intermediary under the new legal framework.

This classification is heavily influenced by company size and whether the merchant receives compensation, commission, revenue share or subsidized payment flows tied to consumer credit.

Enterprise merchants: Companies that meet the EU enterprise threshold (250+ employees, OR >€50 million turnover or >€43 million balance sheet) face direct authorization and licensing requirements from Finansinspektionen. This carries operational burdens, formal reporting requirements and potential personal liability for management and board members.

Mid-market merchants: Smaller businesses escape direct Finansinspektionen licensing, but remain subject to strict oversight from Konsumentverket regarding credit presentation, terms and disclosures.

The 3-point CCD2 readiness check

To determine your business exposure ahead of November 2026, your management team should evaluate three core questions:

1. Are you crossing the enterprise threshold?

• Do you have 250+ employees, >€50M turnover or >€43M balance sheet total?
• Do you actively offer, highlight, or market credit options in your store?

If yes, your business may require licensing and supervision from Finansinspektionen.

2. Are you receiving credit kickbacks?

• Do you receive revenue share, commissions or volume bonuses on credit orders?
• Are your transaction fees subsidized because credit returns finance your payment flow?

If yes, your net margins face immediate pressure as regulatory caps take effect.

3. Can your checkout convert without credit?

• Can your checkout optimize sales across non-credit payment methods?
• Can you steer shoppers to alternative payment options if credit is declined?

If no, your overall conversion rate will take a hit as credit approval rates drop.

The Kustom perspective

Kustom is an independent checkout orchestrator. We do not issue credit, nor is our business model built on downstream debt revenues or kickbacks. Our sole focus is helping merchants build checkouts that convert, adapt and drive sustainable growth.

As the market shifts away from commission-driven credit setups, major players are already adapting. Key BNPL providers have begun phasing out commission-sharing models, capping effective interest rates, and restructuring fee models.

Kustom orchestrates the entire checkout journey — payment options, delivery choices and shopper preferences — ensuring merchants retain full control over conversion without relying on vulnerable credit revenue streams.

The new regulations move Swedish e-commerce toward a reality Kustom was built for: a transparent, flexible and high-converting checkout experience where the merchant owns the customer relationship and margins remain protected.

Want to understand how CCD2 affects your business?

Talk to us about how the new rules can affect your payment agreements, your conversion and your checkout strategy ahead of November 2026.