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Germany’s Debt Rise Puts BNPL Under Scrutiny as EU Credit‑Check Deadline Nears

New rules would require creditworthiness checks even for purchases under €200, with national transposition due by 20 November.

Overview

  • Creditreform’s 2025 Schuldneratlas counts 5.67 million over‑indebted adults, marking a reversal after years of decline.
  • Schufa reports a record 11% of respondents were unable to pay rent or loan installments in the past six months, with young adults the most affected.
  • Destatis says 29% of 2024 debt‑counselling clients owed online or mail‑order retailers, averaging about €644 in online arrears, with higher rates among women and 20–24‑year‑olds.
  • The EU consumer credit directive treats many BNPL and invoice purchases as credit and mandates checks for sub‑€200 financing, with providers citing full compliance by November 2026.
  • Berlin’s implementation talks are live, including a reported SPD idea for written postal consent that retailers such as Zalando criticize and that consumer advocates prefer to handle at least via a digital signature.