CCD2 has been one of the hottest topics in European commerce all year. Much of the conversation has centered on what it could mean in practice, from new labels and creditworthiness checks to updated marketing requirements and new responsibilities across the value chain. It’s natural for merchants to want clarity. And while there is a lot to prepare for, much remains familiar.
At Qliro, regulatory change is part of our everyday work. We have operated under the supervision of the Swedish Financial Supervisory Authority (Finansinspektionen) as a licensed credit market company since 2017. Keeping up with new requirements, adapting our products and processes, and making sure every merchant and consumer can continue to use our services safely and effectively isn’t something we do only when a new regulation arrives. It is part of how we operate.
So, what does CCD2 actually mean for merchants? And what can we learn from previous regulatory changes?
MYTHBUSTING REGULATORY CHANGE
Over the past few years, we’ve navigated several rounds of tightening credit regulations. And each time, a familiar concern has come up:
“Will this hurt conversion?”
Let’s look at what actually happened:
- Myth 1 – Sweden, 2020
Myth: Putting Pay Now ahead of Pay Later in checkout would cost us conversion. The concern was simple – if shoppers saw a debit option first (with more steps to completion and links to external apps) fewer would choose a one-click credit option, potentially reducing completed purchases.
Reality: It didn’t. Conversion increased.
- Myth 2 – Sweden, 2023
Myth: Adding BankID identity verification as an extra step for credit purchases would drag conversion down. The concern was that another checkout step would cause shoppers to drop off before completing their purchase.
Reality: It didn’t. Conversion remained essentially steady.
- Myth 3 – Norway, 2023
Myth: Showing credit status as traffic lights would hurt checkout conversion. Adding more information at checkout can feel risky. Would shoppers stop and reconsider their purchase, or abandon the checkout?
Reality: Again, conversion remained essentially steady.
- Myth 4 – Norway, 2024
Myth: Clearer, standardized credit information (dynamic, downloadable SEKKI) would scare shoppers off. The concern was that adding this extra layer of transparency and a signing step, would make checkout feel heavier and increase drop-off.
Reality: It didn’t. Conversion increased.
- Myth 5 – Sweden, 2025
Myth: A mandatory warning label on credit products would scare shoppers off checkout. A prominent warning about the cost of credit could be expected to make shoppers hesitate, particularly when introduced directly in the checkout journey.
Reality: It didn’t. Conversion increased.
The pattern was the same. Regulatory change didn’t automatically mean checkout friction.
Our priority going into November remains the same. Delivering a checkout experience that shoppers can trust and easily navigate, while keeping conversion front and center. The same priority as with every regulatory shift.
WHAT CCD2 ACTUALLY CHANGES – THE PLAIN-LANGUAGE VERSION
We've got this well in hand, and you can leave a lot to us. But we understand you'll still want to know exactly what's changing.
- Many types of consumer credit are no longer outside the rules. CCD1 exempted interest-free credit, many types of BNPL credits, and short deferred payments. All three exemptions are gone.
- A mandatory warning in all credit advertising, in all markets. Every credit ad must carry a clear and prominent warning that borrowing money costs money.
- Pre-contractual information gets stricter. The SECCI must lead with the key terms on the first page.
- Creditworthiness assessment applies to every credit type, and the answer has to be yes. Previously exempt products are now in scope. Credit may only be granted where the assessment comes out positive.
- Pre-ticked boxes, tying, and unsolicited credit are out. No pre-selected credit options. No bundling credit with another product as a condition, so called auto conversions are banned with CCD2.
- Support before enforcement. Creditors must offer forbearance measures – rescheduling, deferral, reduced rates – if a customer requests this before moving to collection.
- A defined role and a possible license for credit intermediaries. The directive defines a credit intermediary as a business that, without acting as a creditor and for remuneration, presents or offers a credit agreement to consumers, assists consumers by undertaking preparatory work or other pre-contractual administration in respect of credit agreements, or concludes credit agreements with consumers on behalf of a creditor. Businesses that meet that definition may need registration or authorization from the national supervisor. Importantly, merely introducing a consumer to a creditor does not make you an intermediary – and several markets exempt smaller companies from the registration/authorization requirement entirely. Whether any given retailer falls inside, the definition depends on what it actually does and how it is remunerated.
WHAT DOESN'T CHANGE
What doesn’t really change is really the whole point. New rules don't have to mean checkout friction, and we don't expect this one to either.
- The payment methods your customers recognize stay in the checkout. Invoice, monthly invoice, installments, and interest-free campaigns are all still available.
- Where a licensed credit institution is the lender, the regulatory weight – assessment, SECCI, withdrawal handling, automated-decision explanations – sits with that lender, not with you.
- The requirements apply equally to every credit provider in every checkout. Switching provider doesn’t change the rules your customers meet.
ONE MORE MYTH TO BUST
New rules don’t have to mean checkout friction. We’ve seen that before, and we don’t expect CCD2 to be any different. We manage the full journey from checkout to credit decision, which lets us understand, test, and optimize the experience end to end. We prepare for regulatory change, build for it, and continuously improve around it.
Regulation will continue to evolve, and we welcome that. When done right, it can create clearer, more consistent, and more trusted experiences for everyone involved.
Want to know what this means for your setup specifically?
Talk to your contact at Qliro.
Missed our seminar with Cederquist?
Get in touch, and we’ll walk you through the practical steps that came out of it.
Not with Qliro yet?
November is a good reason to have the conversation. One provider, one flow, one team accountable for both the checkout and the credit inside it. Reach out.