In brief
- On 20 November 2026, paying in instalments comes under French consumer credit law. The exclusions that kept it outside disappear: interest-free credit repaid within three months, and credit under €200.
- The lender carries most of the obligations, including the creditworthiness assessment and the pre-contract information sheet, and the customer keeps a right of withdrawal. For short, interest-free credit the sheet is lighter and checking the national register of repayment incidents becomes optional.
- Your “pay in 3, interest-free” banner becomes an advertisement for credit. It must carry the statement “Attention ! Un crédit coûte de l’argent et doit être remboursé” (Warning! Credit costs money and must be repaid), in larger type than any other financing information, and can no longer play up how easy the credit is to get.
- Deferred payment granted by the merchant itself can stay outside the rules: no interest, no third party, settled within fifty days, or fourteen for a large company selling online.
- Credit agreements already running on 20 November stay under the old rules. On our reading, a banner still live that day falls under the new ones.
From 20 November 2026, in most cases, a buy now, pay later plan financed by a provider, in three or four instalments, is consumer credit under French law, even with no interest or fees, even on an €80 basket. The lender assesses creditworthiness, but the advertising on your site now follows the rules for credit. Only deferred payment that you grant yourself, with no third party involved, can stay outside the scope.
Does this apply to you?
- Do you let consumers pay in instalments or later, through a provider or yourself? Then 20 November 2026 concerns you.
- Do your pages, basket or emails promote it, with “pay in 3, interest-free” or “pay later”? Those are credit advertisements, with their mandatory wording.
- Who finances it: a partner lender, or you yourself with no third party? The answer tells you who the lender is, and whether you fall outside the scope.
Why is buy now, pay later becoming credit?
Directive (EU) 2023/2225 on credit agreements for consumers replaces the 2008 directive and applies from 20 November 2026. France transposed it through two government ordinances, dated 3 September and 2 December 2025, followed by a decree of 19 February 2026. All three take effect on that same 20 November.
The French Consumer Code only covered credit between €200 and €75,000, and it excluded credit repayable within three months with no interest or fees, or only negligible ones. The ordinance removes the floor, raises the ceiling to €100,000 and drops that exclusion. The report to the President of the Republic names the target: “split and deferred payments”.
France had little room to manoeuvre: the directive is a maximum harmonisation text, and a member state can only depart from it where it says so. Two of the few options France took up concern exactly these small credits.
For credit repaid within three months with no interest or fees, or under €200, the regime is therefore lighter. The new Article L. 312-4-1 sets aside three of the six advertising disclosures, the mandatory check of the repayment incidents register, the form on the borrower’s income and outgoings, and part of the linked credit rules. The pre-contract information sheet is limited to its first twelve headings. Everything else applies, including the creditworthiness assessment, the fourteen-day right of withdrawal and the ban on pre-ticked boxes.
The lender’s role, and yours
In the usual set-up, a partner institution finances the purchase and pays you the price. It is the lender. It carries out a “thorough assessment” of creditworthiness, on information proportionate to the amount and the term, and social media is not a relevant source. It hands over the information sheet and, if that sheet arrives less than a day before the customer is bound, a reminder of the right of withdrawal.
Your own role is less clear-cut. The Consumer Code defines a credit intermediary as anyone who, for a fee or an economic advantage, helps bring about a credit transaction without being the lender. For registration purposes, the French Monetary and Financial Code draws a more practical line. From 20 November, you are not an intermediary if all you do is point to a lender, without circulating anything other than advertising material supplied or approved by that lender. Businesses that intermediate on an ancillary basis below thresholds set by ministerial order are also exempt, except large companies dealing in consumer credit. Beyond that, registration on the single register of intermediaries kept by ORIAS is required.
On our reading, a shop that only displays its provider’s approved banners stays on the right side of that line; a shop that writes its own messages about the credit moves away from it. Either way, the rules apply to “any advertising”, whoever wrote it.
What changes on your banners and emails?
The provider brings its own process into line after the click. Before the click, your pages and emails speak in your name, and the provider’s compliance does not cover what you write around its offer. The basket thus joins the product page, already governed by the rules on product safety and reference prices.
Any advertising for credit, in any medium, must be clear, fair and not misleading, and carry the statement “Attention ! Un crédit coûte de l’argent et doit être remboursé”. In written advertising, that statement and the annual percentage rate of charge (APR) must appear in larger type than any other information about the financing, “in particular the promotional rate”, within the main body of the text. On our reading, a big “4 interest-free payments” badge with the warning in small print underneath, or missing, is exactly what this provision excludes.
As soon as an advert mentions a rate or a figure linked to the cost of credit, it must also give, through a representative example, the borrowing rate and charges, the total amount of credit and the APR. For interest-free credit, the term, the cash price and the instalment amounts are not required, but beyond three months, say ten instalments, the advert must state any discount for paying cash and who bears the cost of the credit. We treat “interest-free” and “0%” as figures linked to cost, so every short format needs your provider’s sign-off.
The law bans promoting how easy it is to obtain credit, and creating false expectations about its availability or cost. “Instant approval”, “no paperwork”: on our reading, take them out. An older rule also gains weight. Where the financing includes covering the charges, which is what “interest-free” means when you pay the provider’s commission, the seller cannot ask the credit buyer for more than the lowest cash price charged in the thirty days before the advertising began. It is the same window as the reference price rule for price reductions.
Emails have rules of their own. Credit advertising sent by email must remind recipients of their right to object to marketing and, if it mentions a rate or a cost, put the main information in a box at the top of the message. Think about your abandoned basket reminders too, when they mention that customers can pay in instalments.
Your end-of-year creative must comply from 20 November
Credit agreements already running on 20 November 2026 stay under the old law: a payment plan signed on the 19th runs to its end under the old rules. A banner is not a contract. On our reading, any creative still on display on 20 November, including a campaign launched earlier, must meet the new rules that day, and that date is a Friday, one week before Black Friday. The first two steps need nothing more than a spreadsheet and an email.
- List every place where you talk about paying in instalments. Product pages, category pages, basket, checkout, event pages, promotional and automated emails, paid ads, social media. Note the exact wording and who produced it, then look next to it for the sentence “Attention ! Un crédit coûte de l’argent et doit être remboursé”. If it is missing, that is normal: until now, these short, free offers sat outside the scope of credit law.
- Ask your provider, in writing, how it is getting compliant. Find out who the lender is and who assesses creditworthiness, and above all request its compliant advertising templates, format by format, with the version of its plug-in that will display them on 20 November.
- Check your role in the contract. Establish whether you simply point to the lender or actively present the offer, and whether you are a large company under the French Commercial Code. Any registration needs sorting out before the date.
- Replace your home-made copy with the templates. Remove anything about how easy the credit is to get. Check that the instalment option is never pre-selected at checkout, that the credit price does not exceed the lowest cash price of the past thirty days when you cover the charges, and that the order confirmation states that payment is made with credit, as the Code requires whoever the lender is.
- Plan around Black Friday. Produce your end-of-year creative in its compliant version now, rather than planning a switchover on the evening of the 19th. The four other rules to check before 27 November are in our article on what has changed for Black Friday 2026.
Choosing an instalment option
20 November does not treat every offer the same way: it depends on who finances it.
| Family | Who lends, and what is left to you | Who it suits |
|---|---|---|
| Instalments built into your payment provider | The provider or its funding partner. You keep the advertising and the job of checking your role | Shops that want a single integration, on modest baskets |
| Credit from a partner institution | The institution. You keep the advertising, and intermediary status becomes more likely if you present the offer yourself | Higher baskets and longer terms, where guiding the customer matters |
| Payment terms granted by the merchant itself | Outside the rules if settled within fifty days, with no interest, only limited late-payment charges and no third party. Fourteen days, with no sale of the debt, for a large company selling online. Beyond that, you are the lender | Small and medium-sized businesses offering short terms to customers they know |
Nothing stops you offering more than one option: thirty-day terms for loyal customers, a pay-in-four plan handled by a partner, as long as you do not mix the two in the same banner. Beyond the exclusion, a merchant lending on an ancillary basis will have to join a register that a decree is due to set up, unless it is a small or medium-sized business granting interest-free deferred payment.
Your provider’s contract must split the roles and commit to templates
If you are choosing or renegotiating a buy now, pay later solution, check that the contract covers the following points.
- It carries the creditworthiness assessment and the information sheet, and the contract says so.
- It supplies compliant advertising templates for every format, short banner, product page, basket, email, with the warning at the right size.
- It sets out your role in writing, along with the conditions of any exclusion it relies on.
- It dates its templates and tells you when they change.
We recommend having your advertising and your provider’s contract reviewed before 20 November 2026, while your Black Friday creative can still change. That review is part of our e-commerce and marketplaces expertise: ask us for a slot.
Sources
- Ordonnance no. 2025-880 of 3 September 2025 on consumer credit, Journal officiel no. 0205 of 4 September 2025, in particular Articles 4 to 10, 17, 19 and 99, Légifrance (in French). View
- Report to the President of the Republic on Ordonnance no. 2025-880 of 3 September 2025, Légifrance (in French). View
- Ordonnance no. 2025-1154 of 2 December 2025 on consumer credit, Journal officiel no. 0283 of 3 December 2025, Articles 1, 4 and 7, Légifrance (in French). View
- Decree no. 2026-105 of 19 February 2026 on consumer credit, Journal officiel no. 0043 of 20 February 2026, Articles 3, 19 and 30, Légifrance (in French). View
- French Consumer Code, Book III, version in force from 20 November 2026, Articles L. 311-1, L. 312-4 to L. 312-12, L. 312-16 to L. 312-19, L. 312-41, L. 312-42 and L. 312-45, Légifrance (in French). View
- French Monetary and Financial Code, Article R. 519-2, version in force from 20 November 2026, Légifrance (in French). View
- Directive (EU) 2023/2225 of the European Parliament and of the Council of 18 October 2023 on credit agreements for consumers, Articles 2, 3, 7, 8, 37, 47 and 48, EUR-Lex (French language version). View
- Vie publique, “Ordonnance du 3 septembre 2025 relative au crédit à la consommation”, 4 September 2025 (in French). View
- ACPR, “Intermédiaires en opérations de banque et services de paiement” (in French). View