Buy Now Pay Later in Ireland: What the EU Consumer Credit Directive Changes

Buy now pay later in Ireland sits at the intersection of national consumer credit rules and a new EU framework, Directive (EU) 2023/2225, usually called the second Consumer Credit Directive or CCD2. This guide explains what the sources we opened say about BNPL regulation in Ireland today, what the Directive changes, what the Department of Finance has decided about Irish discretions, and what we could not confirm.

It is general information for finance, HR and management professionals, not legal or financial advice. The rules here are changing, so check each official page for the current position.

One important distinction: Irish and UK rules

Much of what is written online about BNPL regulation concerns the United Kingdom. UK rules are not Irish law. If you want the UK position, see our separate UK-rules post on BNPL regulation. This post is about Ireland and the EU.

How BNPL is described by Irish regulators

The Competition and Consumer Protection Commission (CCPC) describes BNPL as a way to spread the cost of purchases over time, interest-free for smaller amounts or with interest and a credit check for higher-value goods. It notes that the shop and the BNPL provider are usually separate companies and that using BNPL creates a separate credit contract. The page text does not show a last updated date; its metadata lists a last-modified date of 31 March 2026.

According to the CCPC, since 2022 BNPL providers must be authorised by the Central Bank of Ireland and follow the Consumer Protection Code, and must check affordability and suitability. Consumers can complain to the Financial Services and Pensions Ombudsman. The CCPC page does not mention the Consumer Credit Directive.

The Central Bank's short-term credit consumer page says new legislation makes hire-purchase, personal contract plans, consumer hire and indirect credit agreements, such as BNPL, regulated activities, and that firms offering them must be authorised. It lists what lenders must do: carry out creditworthiness and affordability assessments, follow specific parts of the Consumer Protection Code 2012, keep advertising clear, fair, accurate and not misleading, meet the Minimum Competency Code 2017 and Minimum Competency Regulations 2017, and submit credit information to the Central Credit Register for loans of 500 euro or more. That page does not show a last updated date and does not mention planned changes.

What Directive (EU) 2023/2225 is

EUR-Lex gives the title as the Directive of the European Parliament and of the Council of 18 October 2023 on credit agreements for consumers, repealing Directive 2008/48/EC. The Department of Finance's regulatory impact analysis (dated May 2024) says the Directive aims to create a harmonised EU framework in a number of core areas, names buy-now-pay-later and other hire purchase products as new products the Directive addresses, and says the Central Bank would regulate firms offering covered credit, with borrowers able to use the Financial Services and Pensions Ombudsman.

This guide does not set out the Directive's articles word for word; read the Directive text on EUR-Lex for that. This guide therefore does not quote article numbers, definitions or the Directive's own scope wording. Where we give scope points below, they are as described in the Irish Department of Finance outcome statement.

Dates

The Department of Finance's CCD2 Public Consultation Outcome Statement (dated August 2025) says the Directive requires the rules to be transposed into national law by 20 November 2025, with the measures to apply from 20 November 2026. It says the Department intends to transpose through Ministerial regulations made under section 3 of the European Communities Act 1972.

The statement describes the plan as of August 2025. This guide does not confirm whether Irish transposition of CCD2 has been completed, so check gov.ie and the Irish Statute Book for the current position. The Central Bank page listing consumer protection legislation, which does not show a last updated date, lists the 2010 Consumer Credit Agreements Regulations (S.I. No. 281 of 2010) and mentions a notice of intention about a Consumer Protection (Regulation of Retail Credit and Credit Servicing Firms) Bill, but does not mention CCD2.

Decisions Ireland has announced on national discretions

The Department of Finance ran a four-week public consultation (19 September to 16 October 2024) on how Ireland should use the 23 national discretions in CCD2. The consultation page, last updated in 2025, says most of CCD2 is fully harmonised across the EU, so the consultation covered only the discretionary provisions. According to the outcome statement:

• Seven of the 23 discretions will be exercised (numbers 7, 10, 11, 13, 14, 17 and 18) and the remaining 16 will not.
• The discretion allowing an exemption for loans under 200 euro, interest-free credit, or credit repayable within three months was not exercised. The Minister decided that the provisions of CCD2 should apply to all credit agreements under 100,000 euro without a lower floor. For BNPL users, that matters because many BNPL products are small and interest-free.
• The statement cites 2023 Central Bank research on how BNPL is used (clothing and footwear, homewares, and medical and dental treatment) as part of its reasoning for not using the small-loan exemption. It also refers to consistency with the Consumer Credit Act 1995, which has no minimum value.
• Ireland will continue to require creditors to consult the Central Credit Register for loans of 2,000 euro or more, and lenders may request a report for smaller loans.
• The exemption for borrowers in or likely to enter default, which would have relaxed creditworthiness assessments, was not exercised.

The outcome statement does not itself designate a competent authority. It says the Department consulted the Central Bank and that the Central Bank's revised Consumer Protection Code should provide all the necessary enforcement powers for consumer credit. The Central Bank's Consumer Protection Code page says the Code took effect on 24 March 2026 following a 12-month implementation period; that page does not mention BNPL or CCD2.

What this means for professionals

Credit data is part of the picture. The Central Bank says BNPL lenders submit credit information to the Central Credit Register for loans of 500 euro or more, and the outcome statement says creditors will be required to consult the Register for loans of 2,000 euro or more. Our guide to the Central Credit Register explains how it works for lenders and borrowers.

For firms that advise, arrange or lend, the Central Bank's page points to the Minimum Competency Code 2017 for regulated short-term credit. Our overview of the Minimum Competency Code and CPD requirements covers the Code itself.

Our suggestion: if your organisation offers or advises on credit products, track the Department of Finance and Central Bank pages for the final Irish transposing regulations, note the application date of 20 November 2026 as stated in the August 2025 outcome statement, and take professional advice on compliance. HR and finance teams can use the CCPC page above as plain-language material for staff questions.

Learnsignal's offices are off Baggot Street in Dublin, and we offer in-person training from there. For current details, see our CPD pages.

Frequently asked questions

Is buy now pay later regulated in Ireland?

According to the Central Bank's short-term credit page and the CCPC, firms offering BNPL must be authorised by the Central Bank and follow the Consumer Protection Code. The CCPC says this has been the case since 2022.

When does the new Consumer Credit Directive apply?

The Department of Finance outcome statement (August 2025) says the measures under Directive (EU) 2023/2225 apply from 20 November 2026, with transposition due by 20 November 2025. Check the Department of Finance page for the current status.

Has Ireland transposed the Directive?

We could not confirm this. The sources we opened describe the intended route (Ministerial regulations under the European Communities Act 1972) but this guide does not identify a specific statutory instrument.

Will small interest-free BNPL loans be covered?

The outcome statement says Ireland decided not to use the exemption for loans under 200 euro, interest-free credit or credit repayable within three months, and that CCD2 should apply to all credit agreements under 100,000 euro without a lower floor.

Does the UK FCA regime apply in Ireland?

No. UK rules are not Irish law. Our UK-rules post covers the UK position separately.

Because transposition details are still developing, rely on the Department of Finance, Central Bank and CCPC pages for the current position.