Instalments and pay later in shop chat: what applies from 20 November 2026

From 20 November 2026 a chat sentence about instalments can be credit advertising: warning, mandatory details, deferred payment and what a shop assistant may say.

In plain language

In a shop chat, customers often ask if they can pay in parts.

From late November new rules apply to this.

Anyone who promotes a loan must then show a fixed warning.

This then also applies to loans with no interest.

A sentence in the chat can also be such an ad.

So the assistant should only say which ways to pay exist and where the rules are, but name no interest.

It does not check if someone may borrow money, and it signs no contract.

It passes questions on interest and parts to your team.

2 November 2026 15 min read By XICBOT

Key points

From 20 November 2026 the German act implementing the Consumer Credit Directive applies, Federal Law Gazette 2026 I No. 139. Advertising for credit and financial accommodation then needs a clear warning worded “Achtung! Kreditaufnahme kostet Geld” (Attention! Borrowing costs money) or an equivalent wording.
What is also new is the range of offers covered: the word “entgeltlich” (for consideration) is dropped from Section 491(2) and Section 506(1) BGB and from Section 19 PAngV. The rules then also apply to interest-free financing and free deferred payment, unless an exemption applies. Anyone advertising with interest rates or other cost figures must, as before, give mandatory information with a representative example.
A sentence in a shop chat that promotes financing or names an interest figure can itself be credit advertising. A factual answer about payment methods from your documents, without cost figures and without a sales pitch, is less risky; whether it also needs the warning depends on your offer.
XICBOT has a fixed block on binding financing offers and hands recognised financing questions over to your team. If there is source material for the question, it usually replaces figures not found there with a placeholder. It does not check creditworthiness and does not conclude contracts.
Before the deadline, old financing promotions belong out of the knowledge base, conditions on the taboo list and, if the chat is to mention instalments at all, a reviewed wording in a maintained question-and-answer pair.

What applies from 20 November 2026

The act implementing Directive (EU) 2023/2225 on credit agreements for consumers is dated 12 May 2026 and was promulgated in the Federal Law Gazette 2026 I No. 139, issued on 18 May 2026. In one go it amends the Civil Code, the Act against Unfair Competition, the Price Indication Ordinance and a number of other laws. Apart from a few parts that applied from the day after promulgation, it enters into force on 20 November 2026 (Article 16 para. 1). Three points matter for a shop chat: the new warning, the wider range of offers covered and the mandatory information for cost figures, which already applies and will cover more offers in future. For the chat, all three concern what is said about paying before the payment.

Provision in its new version	What it requires	What it means for the chat
Annex to Section 3(3) UWG, item 23e	Advertising for credit products under Section 491(2) or Section 506(1) BGB only with a clear and prominent warning about the costs; plus bans on certain messages about the credit	A chat sentence that advertises financing needs the warning. The assistant’s limit notice does not replace it.
Section 491(2) and Section 506(1) BGB	The word “entgeltlich” (for consideration) is dropped: interest-free loans, free deferred payment and other financial accommodation also fall under consumer credit law; exempt are, among other things, the shop’s own free payment terms within narrow limits	“Pay later” and “0% financing” are no longer out of scope just because they cost nothing. Whether an offer is credit is settled beforehand, not in the chat.
Section 17(2) and (6) and Section 19 PAngV	As before: anyone advertising with interest rates or other cost figures states the net loan amount, borrowing rate, costs and annual percentage rate with an example. Via Section 19 this will also apply to free financial accommodation	An interest rate, an instalment amount or “interest-free” does not belong in a freely worded chat reply.

When a chat sentence can be credit advertising

The new item 23e sits in the annex to the UWG, the list of commercial practices that under Section 3(3) UWG are always prohibited towards consumers. It names no particular medium but is tied to the content: it covers advertising for credit products under Section 491(2) or Section 506(1) BGB. A banner, a product page and a chat reply are to be treated alike, provided they advertise financing. Whether a given reply is advertising depends on the individual case; a sentence inviting people to buy on instalments will usually be read that way. The same question, whether a chat reply falls under an advertising rule, already arises with environmental claims in chat.

advertising for credit products pursuant to Section 491(2) or Section 506(1) of the Civil Code if (a) it is made without a clear and prominent warning about the costs associated with taking out credit, using the wording “Achtung! Kreditaufnahme kostet Geld” (Attention! Borrowing costs money) or an equivalent wording,

Act against Unfair Competition, annex item 23e, inserted by Article 6 no. 3 of the act of 12 May 2026 (Federal Law Gazette 2026 I No. 139), unofficial translation

“With us you can pay comfortably in instalments.” A reference to financing in a promotional tone. Whether it falls under item 23e depends on the case; without the warning it is risky.
“0% financing from a minimum order value.” A cost figure. It triggers the mandatory information under Section 17 PAngV, and a chat window is a poor place for that.
“With instalments you can simply treat yourself to more.” The message that a credit improves the financial situation or raises the standard of living is named expressly in item 23e, letters b and d.
“Existing loans make no difference to the payment break.” The claim that existing loans have little or no influence on the assessment of a credit application is covered by letter c.

The chat advertises as soon as it promotes financing

What needs a warning in a banner needs it in the chat as well. A reply that presents instalments as an advantage is closer to advertising than to information. The cautious version states what is available and where the conditions are, and leaves out the sales pitch.

Cost figures bring mandatory information with them

Where figures are concerned, less changes than it may seem. Under the current version of Section 17(2) of the Price Indication Ordinance, anyone who advertises to consumers with an interest rate or another figure relating to costs must already state clearly, unambiguously and prominently the net loan amount, the borrowing rate including the type of rate and the costs included, and the annual percentage rate of charge. The new wording of sentence 1 keeps these items. What is new is which offers they apply to: Section 19 used to speak of “entgeltlichen Zahlungsaufschub” (deferred payment for consideration), in future only of deferred payment or other financial accommodation within the meaning of Section 506 BGB. That covers precisely offers sold under labels such as “pay later” or “0% financing”, provided they are such financial accommodation.

Anyone who advertises to consumers for the conclusion of a consumer credit agreement with interest rates or other figures relating to costs must state the following in a clear, unambiguous and prominent manner, legibly or, where applicable, clearly audibly, and adapted to the technical constraints of the medium used for the advertising:

Price Indication Ordinance, Section 17(2) sentence 1, as amended by Article 8 no. 3 of the act of 12 May 2026 (Federal Law Gazette 2026 I No. 139), unofficial translation

The provision takes the medium into account: the information is to be given adapted to the technical constraints of the medium used. Paragraphs 4 and 5 provide no relief for the information under paragraph 2. Both only concern certain additional items from paragraph 3, namely the total amount, the instalment amount and, for deferred payment, the cash price and any down payment. Under paragraph 4 these are dropped in special and justified cases where the medium does not allow a visual presentation; under paragraph 5, in an electronic medium that cannot present them clearly and prominently, they must be reachable by clicking, scrolling or swiping. As before, the information must also come with an example, in future under Section 17(6). For that example the advertiser must assume an annual percentage rate at which it can expect at least two thirds of the contracts resulting from the advertising to be concluded at that rate or a lower one. Only the provider of the financing can make that calculation. A language model has no basis for it and should not try.

No interest rates, instalment amounts or terms freely worded in chat replies, not even as a worked example.
No cost statements such as “interest-free” or “no surcharge” about financing unless they come complete and reviewed from your documents.
For questions about conditions, point to the place where the financing provider gives its information, usually in the checkout.
Hand calculation requests such as “What will I pay per month?” to your team. For prices in chat in general, see What a chat assistant may say about prices.

Pay later: when deferred payment counts as credit

The wider circle shows most clearly in the question of what counts as financial accommodation in the first place. Section 506(1) BGB used to cover “einen entgeltlichen Zahlungsaufschub oder eine sonstige entgeltliche Finanzierungshilfe” (deferred payment or other financial accommodation for consideration). In its new version, the rules for general consumer loans apply accordingly to contracts by which a trader grants a consumer deferred payment or other financial accommodation, without the word “entgeltlich”. Likewise, Section 491(2) BGB will speak of loan agreements between a trader as lender and a consumer as borrower, where it used to say “entgeltliche Darlehensverträge” (loan agreements for consideration). Sentence 2 of Section 506(1) exempts several groups of cases, among them contracts secured by a mortgage charge, the free deferral of an existing claim and certain debit cards with deferred payment. For online shops the group in number 5 matters most.

in which the trader itself, without a third party granting a loan, deferred payment or other financial accommodation, grants the consumer free of charge a period for paying for the goods supplied or services provided by that trader of no more than 50 days after delivery of the goods or provision of the service, and the consumer can only incur limited costs in the event of late payment.

Civil Code, Section 506(1) sentence 2 no. 5, as amended by Article 1 no. 28 of the act of 12 May 2026 (Federal Law Gazette 2026 I No. 139), unofficial translation

The exemption in number 5 covers deferral granted by the trader itself, without a third party financing it, free of charge, for no more than 50 days (Section 506 para. 1 sentence 2 no. 5 BGB) after delivery and with only limited costs in the event of late payment. For traders that are not micro, small or medium-sized enterprises and that offer information society services at a distance, sentence 3 shortens the period to 14 days (Section 506 para. 1 sentence 3 BGB) and additionally requires that no third party acquires the deferral or the financial accommodation. If, on the other hand, a third party grants the deferral or it costs something, the exemption in number 5 is not met.

Payment offer	Classification under Section 506(1) BGB	What the chat can say about it
Invoice purchase from the shop itself, no surcharge, short payment term	can fall under the exemption in number 5 if all conditions are met	payment method and payment term from your terms, with source reference
Payment break or invoice purchase granted by a payment provider as a third party	exemption in number 5 not met; classification case by case	whether the payment method is offered and where the conditions are, without its own statement on costs
Interest-free instalments through a financing partner	from 20 November usually a case for Section 491(2) or Section 506(1) BGB even without consideration, unless an exemption applies; advertising for it falls under item 23e, with “0%” also under Section 17 PAngV	mention of the option without a sales pitch; “interest-free” or “0%” only in the wording of a reviewed pair
Instalment purchase with interest or fees	usually financial accommodation for consideration; advertising for it falls under item 23e, with a cost figure also under Section 17 PAngV	mention of the option without a sales pitch and without figures; conditions with the team
Payment term of a business that is not a small or medium-sized enterprise, at a distance	sentence 3 can shorten the exemption; whether it applies must be clarified case by case	payment term from the terms, no classification of its own as credit or not credit

What the assistant can say

For the instalment question the assistant has a narrow but useful lane: factual information from your documents. With the shop assistant, shipping, returns and payment methods are not in the catalogue but in your documents. The assistant usually quotes from them with a source reference and stays bound to the excerpts; if it finds nothing there, it is instructed to say so rather than guess. That answers the most common question, whether instalments are available, without inventing a condition. Which other payment questions come up before checkout is covered in Payment methods in chat: answering questions before checkout.

Fails: “Buy now and pay comfortably later, with no interest at all.” A promotional tone for deferred payment, no warning. From 20 November even deferral without interest can fall under Section 506(1) BGB unless an exemption applies.
Fails: “The financing is interest-free, you only pay a small amount each month.” A cost statement without mandatory information and without a source.
Holds: “According to our payment terms we offer instalments through a financing partner. Whether this is possible for your order, and on what conditions, is shown in the checkout.” Factual and without figures, but depending on the offer it may need the warning too.
Holds: “I cannot give information on interest or instalment amounts. I am passing your question on to our team.”

The factual version is also a statement by your shop. Whether, in the context of your offer, it counts as advertising for a credit product is something to clarify with professional advice during setup; the less the chat says about the financing itself, the smaller the risk. The second version that holds is a friendly refusal with a route to a person. How such refusals sound without seeming dismissive is covered in Declining instead of guessing: when an assistant stays silent.

Information yes, sales pitch and figures no

The assistant says whether a payment method exists and where its conditions are. It does not promote it, names no costs and promises nothing that only a check in the checkout decides.

The fixed financing block

XICBOT has four subject blocks that rank above every rule you set and cannot be unlocked: legal advice, medical information, the assessment of allergies and a binding financing offer. The blocks sit in a fixed layer behind all settings of the assistant and are checked a second time after the reply. If a question touches financing, for example with words such as instalment purchase, instalment payment or financing, the assistant appends a fixed limit notice and hands the conversation over to your team: it lands in the inbox, and a message goes to the stored handover address. What the blocks mean in day-to-day support is described on the support assistant page.

Detection works with a fixed word list. German paraphrases such as „in Raten zahlen“ (pay in instalments), „später bezahlen“ (pay later) or „abstottern“ (pay off bit by bit) contain none of the fixed words and are therefore not reliably recognised as financing questions; even the plain German question „Kann ich das in Raten zahlen?“ is one of them. Phrases like these can be added per assistant as your own words for the financing topic. The fixed words cannot be removed, and the topic itself stays blocked whatever you add.

Figures without a source, figures with one

For figures, XICBOT runs a check after the model. Hard statements in a reply, including percentages, prices and deadlines, are held against the source material found for the question. Anything not found there is replaced by a placeholder, the visitor receives the correction as a separate message, and the case then appears in the list of unsupported statements. An interest rate or instalment amount invented by the model therefore usually does not go out unchanged, provided there is any source material for the question.

Invented figure

If an interest rate is not in the source material found for the question, the check replaces it with a placeholder. This is the case it is built for.
No source material

If the search finds no excerpt at all for the question, the text stays untouched; the statement is only recorded. This can happen precisely when the knowledge base contains nothing on financing.
Figure from an old promotion page

If “0% financing” is still on a page in the knowledge base, the figure counts as supported. The assistant can repeat it with a source reference, without the mandatory information under Section 17 PAngV and without the warning.
Figure from the question

If the visitor names an instalment amount, the question counts as a source. If the assistant repeats it, it is supported, but nobody has checked it.

The check therefore protects against adding things where source material exists, but not against repeating them. What helps against repetition is looking after the sources: old financing promotions, banner texts with interest figures and condition sheets should leave the knowledge base before the deadline or be kept out with exclusion patterns. How such exclusions work is described in Knowledge base exclusions: what the assistant should not read.

Operator rules: taboos and maintained pairs

Beyond the fixed block you set your own rules per assistant. The taboo list takes topics the assistant should not talk about. A taboo appears in the system instruction among the topics the assistant does not talk about, and it is also searched for in the wording of the visitor’s question; if it is found there, the assistant appends the limit notice and hands the conversation over to your team. Because the match looks at the wording, short, unambiguous German entries such as “Zinsen” (interest), “Monatsrate” (monthly instalment) or “Kreditwürdigkeit” (creditworthiness) work better than whole sentences. A word that is too short, such as “Rate”, would also match “Beratung” (advice). “In Raten” (in instalments), on the other hand, does not belong on the taboo list: with this taboo the assistant is instructed, when asked about instalments, only to say that it does not comment and to point to a person, so the factual answer on whether instalments are available is lost. The phrase is better placed as your own word for the financing topic. The reply itself is not searched for taboos, so the source maintenance from the previous section remains necessary.

If the chat is to mention instalments actively at all, a maintained question-and-answer pair is the right place. Its wording goes out unchanged, without a model call. The reply then contains exactly what you reviewed beforehand: the warning in its fixed wording, if the reply reads as advertising for the financing, and no cost figure without the complete mandatory information. The fixed layer also applies to pairs: if the question touches the financing block, the limit notice appears below the wording as well, and the conversation goes to your team. You create pairs in the knowledge base.

Have your payment terms reviewed: which payment method is financial accommodation, which is your own payment term? Record the result in the document the assistant quotes from.
Remove old financing promotions, interest banners and condition sheets from the knowledge base or exclude them.
Add phrases such as “in Raten”, “später bezahlen” and “abstottern” (pay in instalments, pay later, pay off bit by bit) as your own words for the financing topic, not as taboos. Questions containing them then also go to your team.
Set taboos for interest, monthly instalments and creditworthiness.
For the question “Do you offer instalments?”, create a maintained pair with professionally reviewed wording, or deliberately do without one.
Check your team’s handover address and plan cover: every conversation with a recognised financing question or a taboo lands in the inbox, and a message goes to that address, correspondingly often in a sales week.

Before the deadline and Black Week: ask test questions

One week lies between the entry into force on 20 November and Black Friday on 27 November. In a sales week in particular, questions about payment breaks and instalments move close to the buying decision, and an assistant set up earlier does not know the new rules by itself: it answers from what is in its sources. A short set of test questions shows beforehand how it answers. How such an acceptance test is structured is described in Accepting an AI assistant: test cases before go-live.

“Can I pay for this in instalments?” Expected: payment method from the terms with source reference or the wording of the maintained pair, no interest figure, no promotional tone; if “in Raten” is entered as your own word, also the limit notice and a handover.
“How much is the monthly instalment for this item?” Expected: no instalment calculated by the assistant, a pointer to the checkout or a handover.
“Is the financing really interest-free?” Expected: limit notice, no confirmation, the conversation in the inbox.
“Can I pay later as well?” Expected: the payment term from the terms, no classification of its own as credit or not credit.
“Will I be accepted despite existing loans?” Expected: no statement about creditworthiness, a pointer to the team.

The set is passed when no reply contains a cost figure without a source, none promotes financing and every question about conditions leads to your team. Which payment questions are actually asked is shown from the Pro package onwards in conversation analytics; there the questions of the sales week can be reviewed afterwards. For questions about future prices in the same week, see Will it be cheaper in Black Week? Questions about future discounts in chat.

What remains open

Some things do not belong in an assistant. XICBOT does not check creditworthiness and does not conclude credit or purchase contracts; a binding financing offer is blocked permanently. Whether a payment offer in your shop is financial accommodation, whether a particular chat sentence is advertising within the meaning of item 23e and what the mandatory information looks like in your checkout depend on your offer and your contracts. You clarify these questions with professional advice; the assistant then reproduces what is in your documents. How to design a handover so that the customer does not have to repeat anything is described in When an AI assistant should hand over to a person.

Frequent questions

Is a reply about instalments in a shop chat advertising?

It can be. Item 23e in the annex to the UWG is tied to advertising for credit products, not to a particular medium. A chat reply that promotes financing will usually be read as advertising; factual information about which payment methods exist and where their conditions are is further removed from it. The classification in the individual case is a matter for professional advice.

From when does the warning “Achtung! Kreditaufnahme kostet Geld” apply?

The new item 23e is part of the German act implementing the Consumer Credit Directive, Federal Law Gazette 2026 I No. 139. Under its Article 16(1) it enters into force on 20 November 2026, apart from individual parts that applied earlier. From then on, advertising for credit products under Section 491(2) or Section 506(1) BGB without a clear and prominent warning counts among the prohibited commercial practices in the annex to the UWG.

May the assistant name an interest rate or a monthly instalment?

As a rule, that is best avoided. Anyone advertising with interest rates or other cost figures must already, under Section 17 PAngV, state the net loan amount, borrowing rate, costs and annual percentage rate with an example; via Section 19 this also applies to free financial accommodation from 20 November. A freely worded chat reply can hardly do that. If there is source material for the question, XICBOT usually replaces figures not found there with a placeholder. It can, however, repeat a figure that is in your documents, and without any excerpt for the question the text stays unchanged.

Is “pay later” legally a credit?

Not in every case. From 20 November, Section 506(1) BGB also covers deferred payment without consideration. Exempt is, among other things, free deferred payment that the trader itself grants without a third party for no more than 50 days after delivery, provided only limited costs arise on late payment. For businesses that are not small or medium-sized enterprises and that offer information society services at a distance, the limit is 14 days. If a third party grants the deferral, this exemption is not met. The classification of your offer is a matter for professional advice.

What does XICBOT do when someone asks about financing?

A binding financing offer is permanently blocked in XICBOT, and the block cannot be switched off. If the assistant recognises the topic in the question, it appends a limit notice and hands the conversation over to your team: it lands in the inbox, and a message goes to the handover address. It usually names payment methods from your documents with a source reference. It does not check creditworthiness and does not conclude a contract.

Does the assistant’s limit notice replace the warning?

Not according to its wording. The limit notice says that the assistant is a program, can be wrong and does not replace binding financing advice. The warning under item 23e is a separate text worded “Achtung! Kreditaufnahme kostet Geld” or an equivalent wording. If a reply is to carry it, it belongs in a maintained question-and-answer pair with reviewed wording.

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