CCD2 is sorted. Now ask the harder questions
A new regulation has landed in Germany. For most BNPL providers, it means new compliance steps, additional verification, and changes to the checkout experience. For merchants using Riverty’s 14-day invoice, the situation is currently simpler – this product is temporarily exempt from these requirements, so the checkout experience stays as it is; no additional friction, no new steps for your customers. For merchants in Germany, it’s a concrete advantage at a moment when competitors are adding steps.
A simpler checkout is the door-opener. CCD2 has put every merchant’s BNPL setup under a microscope. And once you’re looking, there’s a more important question to ask – one your current provider perhaps would rather you didn’t.
Compliance is a floor, not a ceiling
Meeting regulatory requirements means your checkout is legal – it doesn’t tell you whether your BNPL provider is actually working for your business, or quietly working against it.
Here are the questions worth asking now
1. After checkout, where do your customers go?
The payment completes, the order is confirmed – and then what? If your BNPL provider has its own consumer app, its own marketplace, or its own shopping destination, there’s a reasonable chance your customer is being redirected there.
This isn’t just a theoretical concern: Several major BNPL providers have built consumer ecosystems that depend on keeping shoppers engaged on their platforms, surfacing other brands, other deals, other reasons to spend. The checkout is the entry point; your customer becomes their customer.
Riverty, however, has no consumer marketplace. No competing shopping destination, no reason to redirect your customers anywhere other than back to you. The relationship your customer has at checkout stays with your brand.
For fashion merchants, where brand loyalty is hard-won and easily disrupted, this matters more than most providers will volunteer.
For beauty merchants, where repeat purchasing depends on a consistent, trusted brand experience, this should be examined closely.
2. Who owns the data generated at your checkout?
Every transaction generates data. Purchase behaviour, product preferences, spend patterns, return rates all create a detailed picture of how your customers shop. The question is, what does your BNPL provider do with it?
Some providers use merchant checkout data to inform their own consumer-facing products. They may use it to reach your customers with competitor advertising, to build consumer profiles for their marketplace, or to refine targeting for other brands in their ecosystem. So the data generated at your checkout, by your customers, essentially powers someone else’s business model.
Riverty does not run a consumer marketplace; it does not use merchant checkout data to compete for your customers’ attention elsewhere. The data that flows through your payment experience remains in service of your business relationship, not someone else’s growth strategy.
In an environment where first-party data is increasingly valuable – and increasingly difficult to protect – it’s worth knowing exactly where yours goes.
3. What happens after payment is made?
Fashion
Roughly 39% of BNPL invoices in fashion contain a return. That’s not a problem – it’s a structural reality of the category. But what happens next?
Does your provider handle the return cleanly, automatically reconciling the payment and updating the invoice without requiring manual intervention from your operations team? Or does the complexity land back on your side?
Returns that are handled badly don’t just create operational cost – they erode customer trust at exactly the moment you need it most, when a customer is deciding whether to buy from you again. A clean return experience is a loyalty driver; a complicated one isn’t.
Beauty
When a customer makes three purchases in a month – a routine restock, a seasonal drop, an impulse add-on – do they receive three separate invoices with three different payment timelines, or does your provider consolidate them into a single, clear payment experience? Invoice fragmentation is one of the leading causes of payment confusion in beauty ecommerce. Customers lose track, reminders feel disconnected from the brand, and the experience becomes administrative rather than effortless. In a category built on repeat purchasing and routine, that friction compounds quietly – until a customer decides it’s easier to shop somewhere else. Payment continuity isn’t a nice-to-have; it’s a retention mechanism.
The minimum expectation is exactly that: minimum
A BNPL partner that keeps your checkout compliant is doing what you’re paying them for. The harder question is whether your provider’s business model is aligned with yours, or structured around competing with it.
A partner whose only business is serving merchants – not building a consumer marketplace, not monetising purchase data, nor redirecting customers to a competing destination – looks different, and over time, it compounds differently.
Compliance sorts the floor. Now you know what to build on it.
Frequently Asked Questions
CCD2 – the Consumer Credit Directive 2 – is a European regulation introducing new compliance requirements for BNPL providers across EU markets including Germany. It covers updated payment flows, Strong Customer Authentication, revised consumer credit disclosures, advertising restrictions, late payment cost caps, and mandatory age verification. The regulation is already in effect, with requirements being phased in across markets.
For fashion merchants, CCD2 creates a divergence at checkout. Providers who aren’t exempt from the new requirements are adding verification steps – introducing friction at a point where conversion is already fragile. Beyond the compliance question, CCD2 creates a natural moment to ask whether your BNPL provider’s business model is genuinely working for you; or quietly working against you.
Compliance is the minimum expectation, not the measure of a good partner. The questions worth asking go beyond the regulation: Does your provider redirect your customers to their own marketplace or shopping destination after checkout? Who owns the data generated at your checkout, and what is it being used for? And when something goes wrong – a return, a dispute, a payment query – does your provider handle it cleanly, or does the complexity come back to your team? CCD2 has created the moment to ask; these are the questions worth asking in it.
Integrate BNPL into your business to increase your sales
Find out how BNPL can increase your sales, customer satisfaction, and competitive edge.