When is an invoice counted as consumer credit?

Invoice payment may be treated as consumer credit where payment is deferred beyond certain thresholds, or where a third party issues or acquires the invoice so that an exemption does not apply. The assessment depends on how the payment terms are structured and whether the consumer effectively receives credit.

When must a creditworthiness assessment be performed for invoice payment?

A creditworthiness assessment is required where the invoice solution qualifies as consumer credit, meaning the credit decision must be based on sufficient information and documented with a traceable method. This is particularly relevant where payment is significantly deferred, split into instalments, or handled through certain third-party set-ups.

How should pre-contract information about invoice credit be provided?

Pre-contract information must be provided in good time before the consumer is bound, be clear and comprehensible, and be made available on a durable medium. It should include, among other things, the annual percentage rate, fees, due date, payment terms and the consequences of default, with further requirements applying under CCD2 from 20 November 2026.

Invoice credit

Read more about when an invoice becomes consumer credit under the new regime applicable from 20 November 2026, and what this means for requirements, responsibilities and licensing.

Glossary
Invoice credit

Explained – what does invoice credit mean?

An invoice will constitute consumer credit where payment is postponed or split into instalments—provided the exemptions in the consumer credit directive are not applicable and the baseline assumption is that no third party issues the invoice. This credit type will be financially regulated and fall under the consumer credit law and the EU’s second consumer credit directive, Directive 2023/2225 (CCD2). CCD2 will apply from 20 November 2026 and introduces new or tightened requirements for certain invoice solutions. Until then, current Swedish rules apply, with the definition set out in Section 2 of the Swedish Consumer Credit Act (2010:1846).

Where credit is provided on a professional basis, the activity may become subject to licensing under the forthcoming Act on Housing Credits and Certain Other Consumer Credits. Licensing may be required in the role of lender or credit intermediary, depending on the set-up. CCD2 broadens the scope at EU level from 20 November 2026 and clarifies rules for deferred payment by invoice, partial payment or instalments and “buy now, pay later” solutions.

When does invoice credit qualify as consumer credit?

The question arises where a business grants a payment deferral longer than 50 days, or longer than 14 days where a large operator offers goods or services online. Another common scenario is where the invoice is issued by—or in some cases assigned to—a third party (for example a factoring company), which may mean the credit no longer benefits from an exemption. The assessment turns on how the payment terms are structured and, if the consumer receives something akin to credit, it is likely to be captured by these new rules.

If invoice payment constitutes consumer credit under the future law, the rules for consumer credits apply. This includes requirements such as pre-contract information and creditworthiness assessment under the consumer credit law, together with additional organisational requirements, including licensing under the updated Act on Housing Credits and Certain Other Consumer Credits.

Businessman pointing at euro invoice with calendar and payment icons, illustrating invoice credit, factoring and short-term business financing solutions.

Points to consider when offering invoice credit

Businesses that offer invoice payment themselves or through third-party partnerships need order and clarity across both contract terms and processes. The following are central points to embed in operations.

Determine whether the payment terms constitute a credit under the definition in the updated consumer credit law.
Conduct and document a creditworthiness assessment before granting invoice payment where it is consumer credit, with sufficient decision data and a traceable methodology.
Provide pre-contract information on a durable medium, including the annual percentage rate, fees, due date and terms for default interest.
Present the annual percentage rate and total cost clearly and transparently.
Establish internal guidelines for handling late payments, reminders and debt collection in line with good debt-collection practice.
Assess whether a licence is required for lending or credit intermediation.
Ensure marketing complies with the information requirements in CCD2 (the consumer credit directive).

A correctly classified and clearly communicated invoice solution strengthens compliance and increases transparency for the consumer. Without a proper assessment, a business risks carrying out licensable activity without a licence.

Invoice credit

Why invoice credit matters

Invoice credit determines which information obligations, controls and licences are required. When an invoice becomes consumer credit, the consumer credit law applies. From next year, certain requirements will be introduced and tightened under the updated Act on Housing Credits and Certain Other Consumer Credits. Proper execution makes terms and costs understandable for consumers and facilitates comparisons between payment options.

For businesses, correct application ensures information duties are met, credit decisions are documented, and costs are disclosed openly. This supports sound lending and responsible communication about payment options.

Accurate classification and clear terms build trust between merchants, lenders and customers. This leads to fewer complaints, more stable payment flows and a more predictable purchasing experience over time.

An invoice will be counted as consumer credit where payment is deferred by more than 50 days, where the invoice is issued by a third party or, in some cases, where it is assigned. For larger online providers, the threshold is 14 days.

Where payment is deferred by more than 50 days, where the invoice is issued by a third party or, in some cases, where it is acquired by a third party, or where it is offered by a large online provider and payment is deferred by more than 14 days.

Information must be provided in good time before contract, be clear and comprehensible, and be available on a durable medium. It must include, among other things, the annual percentage rate, fees, payment terms and consequences of default. Certain requirements will be tightened under CCD2 from 20 November 2026.

The main rules on what constitutes consumer credit are found in the Swedish Consumer Credit Act (2010:1846). Regulation of the activity and supervision will follow from the new Act on Housing Credits and Certain Other Consumer Credits.

The lender is primarily responsible. However, where the seller acts as a credit intermediary, as defined in CCD2, the seller has its own responsibility to ensure information is provided correctly and on time.

Documentation should evidence that the consumer received the correct information before the contract was concluded and that the credit decision was taken in accordance with the rules. For example: