FitStep 1
What you are offering
We analyze whether your scheme is an excluded deferral, consumer credit that you grant yourself or financing from a third party.
Art. 3 Law 16/2011.
Customer financing and installment payments in Spain
If you run a shop, clinic, academy or e-commerce business and want to get paid in installments, we tell you whether what you offer is consumer credit, whether you act as an intermediary for a finance company, and which contracts, disclosures and registrations you need. So you can sell more without problems with your customers or the consumer authorities.
Want to offer installment payments to your customers?
Tell us what you sell, the average amount and how you want to be paid, and we will tell you which regime applies and what it costs to set it up properly.
- Reply within 24 h
- No commitment
- Confidential
- Credit excluded from Law 16/2011
- < 200 €
- Maximum charges on a 3-month deferral
- 1 %
- Consumer withdrawal right
- 14 days
- Own deferral excluded under CCD2
- ≤ 50 days
What we do
Installment payments for your customers, set up properly from the start
Getting paid in installments can be a simple deferral, consumer credit that you grant yourself or financing from a third party. Each option has different rules.
ModelStep 2
We choose the model
Own deferral, own credit, partner finance company or deferred payment provider: we tell you what each one means for your business.
Cost, risk and obligations.
DocumentsStep 3
Contract and disclosures
If it is consumer credit, we prepare the contract, the standard European information and the creditworthiness assessment.
Arts. 10, 14 and 16 Law 16/2011.
Finance companyStep 4
Agreement with the finance company
We review the contract with the finance company or deferred payment provider: fees, liability and what happens if the customer withdraws.
Linked contracts, art. 29.
AdvertisingStep 5
“0%”, “interest-free”, “in installments”
We review your ads, website and shop so that your installment payment advertising complies with the disclosure rules.
Art. 9 Law 16/2011.
FutureStep 6
Ready for CCD2
The new directive brings deferred payment within the scope of consumer credit. We get you ready for when the Spanish law is approved.
Directive (EU) 2023/2225.
Scenarios
Businesses that sell in installments
These are the sectors that consult us most. The amount and who bears the risk change the regime.
Clinics
Dental, cosmetic or fertility treatments
The amounts are high and many clinics finance their patients, on their own or with a finance company. This usually involves consumer credit or a linked contract.
Training
Academies, master’s programs and courses
Splitting the tuition fee is common. If there is interest, charges or a long term, it stops being a simple deferral.
E-commerce
Online shops with deferred payment at checkout
Deferred payment providers take on the credit, but your shop still has disclosure and advertising obligations.
Services
Workshops, renovations, gyms and subscriptions
Monthly fees, minimum commitment periods and deferred payments: we need to see whether the contract disguises a financing arrangement.
What the law says
Installment payments in figures
Data from Law 16/2011, currently in force, and Directive (EU) 2023/2225.
Art. 3.c Law 16/2011
€200
Credits with a total amount below €200 fall outside the law currently in force.
Art. 3.f Law 16/2011
Free
Credits with no interest or any other charges are also excluded.
Art. 3.f Law 16/2011
3 months and 1%
As are those repaid within 3 months at most with minimal charges, which cannot exceed 1% of the amount.
Art. 3.f Law 16/2011
Presumption
In linked contracts, the seller is presumed to pay the lender, and the credit is then not considered free of charge.
Art. 28 Law 16/2011
14 days
Period during which the consumer may withdraw from the credit contract without giving any reason.
Art. 2.2.h Directive 2023/2225
50 days
The new directive only excludes a deferral granted by the seller itself, at no cost and with no third party, to be repaid within a maximum of 50 days.
Shall we review your installment payments?
Tell us how you want to be paid and we will tell you which model suits you and what you need to offer it safely.
Frequently asked questions
Customer financing: frequently asked questions
Can I get paid in installments without being a financial institution?
Yes. A business can defer payment for its customers or grant them credit with its own funds. What changes is the regime: if the deferral is free of charge, it falls outside Law 16/2011 (art. 3.f); if there is interest or charges, you are granting consumer credit and its disclosure, creditworthiness and contract obligations apply to you.
If I do not charge interest, does the law apply?
Today, if the credit is genuinely free of charge (no interest or any other charges) or is repaid within 3 months with minimal charges of up to 1%, it falls outside Law 16/2011. But be careful: if you finance through an institution, the law presumes that you pay it a commission and the credit is then not considered free of charge.
What happens if I work with a finance company?
The loan is granted by the finance company, but your sale and its credit form a linked contract: if you do not deliver what was sold, the customer can assert this against the finance company (art. 29 of Law 16/2011). In addition, when you present or process its credit you act as an intermediary and have disclosure obligations; depending on how you do it, registration may be required. We cover this in consumer credit intermediary.
What if I use a deferred payment provider in my online shop?
The provider takes on the credit and its obligations, but you control how it is advertised and how it is presented on your website. Make sure the information is clear and that you do not promise terms that do not apply. More about these models in deferred payment (BNPL) regulation.
What changes with the new consumer credit directive?
Directive (EU) 2023/2225 widens the scope: it includes deferred payment and credits of less than €200, and only leaves out a deferral granted by the seller itself, at no cost and with no third party, to be repaid within a maximum of 50 days. Member States must apply it from November 20, 2026, but Spain has not yet approved its law, so Law 16/2011 will remain in force until it does.
What documents do I need if I grant credit myself?
Standard pre-contractual information (art. 10), a creditworthiness assessment of the customer (art. 14), a written contract with its minimum content (art. 16) and information on the 14-day right of withdrawal (art. 28). You must also review your advertising (art. 9). We explain this in pre-contractual information.
What if my customers are businesses?
Law 16/2011 protects consumers. If you sell to companies or self-employed professionals for their business activity, the deferral is governed by what you agree and by commercial law, although it is advisable to review payment terms and guarantees.
Practical guide
How we set up your installment payments
We organize it into three decisions that you make, with our help.
Who finances
You, a finance company or a deferred payment provider.
What it costs
Free, with limited charges or with interest.
Over what term
A few weeks, a few months or long-term financing.
Your installment payments in 10 steps
- We describe what you sell, the average amount and the type of customer.
- We check whether your customers are consumers or businesses.
- We classify your scheme: excluded deferral or consumer credit.
- We choose the model: own credit, partner finance company or deferred payment provider.
- If you provide the financing, we prepare the contract and the pre-contractual information.
- We design a proportionate creditworthiness assessment.
- If you work with a finance company, we review the agreement and your role as intermediary.
- We review the advertising of your installment payments on your website and in your shop.
- We prepare the procedure for withdrawals, returns and non-payment.
- We leave you with a plan to adapt to the new consumer credit law.
Source: Law 16/2011 (arts. 3, 9, 10, 14, 16, 28 and 29) and Directive (EU) 2023/2225 (art. 2).
Working glossary
Key concepts in installment payments
Terms from Law 16/2011 and Directive (EU) 2023/2225.
CreditConcept
Consumer credit
Deferral, loan or other financing granted to a consumer.
Art. 1 Law 16/2011.
DeferralExcluded
Free deferral
Deferred payment with no interest or charges, which today falls outside the law.
Art. 3.f Law 16/2011.
LinkedContract
Linked credit contract
Credit that finances a specific purchase and forms a commercial unit with it.
Art. 29 Law 16/2011.
IntermediaryRole
Credit intermediary
A person who presents, offers or processes a lender’s credits in return for remuneration.
Law 16/2011 and Law 2/2009.
APR (TAE)Cost
Annual percentage rate
Total cost of the credit expressed as an annual percentage; it must appear in advertising.
Art. 9 Law 16/2011.
BNPLModel
Deferred payment (buy now, pay later)
Financing of the purchase at the point of sale, normally short-term.
Directive (EU) 2023/2225.
Playbook
The four models and what each one requires of you
Free own deferral
What it is: You defer payment, with no interest or charges.
What it requires of you: Today, falling outside Law 16/2011; under CCD2, 50 days maximum.
Own credit with interest or charges
What it is: You grant the credit to your customer.
What it requires of you: Full Law 16/2011: disclosure, creditworthiness, contract and withdrawal.
Partner finance company
What it is: An institution grants the credit and you offer it.
What it requires of you: Intermediary obligations and linked contract.
Deferred payment provider
What it is: A third party pays for the purchase and collects from the customer in installments.
What it requires of you: Review the agreement, the disclosures and the advertising.
Common mistakes when selling in installments
These are the ones we see most in shops and clinics.
- Advertising “0%” when the customer pays fees or insurance.
- Treating a credit as free when the finance company charges the seller a commission.
- Not providing pre-contractual information when the business itself grants the credit.
- Forgetting the 14-day right of withdrawal.
- Presenting a finance company’s credits without reviewing the intermediary obligations.
Contact
Book a call
Tell us what you sell, the average amount and how you want to be paid in installments, and we will prepare a diagnosis and a tailored quote.
Installment payments under Law 16/2011 and the new directive
Updated November 4, 2026
Selling in installments is granting credit: the seller lets the customer pay later. If the customer is a consumer, Law 16/2011 on Consumer Credit Agreements applies, except in the cases excluded by its art. 3.
What is excluded today
The law does not apply to credits of less than €200, to credits granted free of interest and of any other charges, or to those repaid within 3 months with minimal charges of up to 1% (art. 3). In linked contracts, the law presumes that the seller remunerates the lender and, unless otherwise agreed, the credit is not considered free of charge. We explain this in which credits fall outside the rules (in Spanish).
If you grant the credit or a third party does
If you grant the credit yourself with interest or charges, you are a lender and the obligations on disclosure, creditworthiness, form of the contract and withdrawal apply to you (arts. 9 to 16 and 28). If a finance company grants it, the purchase and the credit form a linked contract (art. 29) and you act as a credit intermediary.
What will change
Directive (EU) 2023/2225 brings deferred payment and credits of less than €200 within its scope, and only excludes the seller’s own deferral with no cost and no third party for 50 days at most (art. 2.2.h). Member States must apply it from November 20, 2026, but Spain has not yet approved its law. We summarize it in the consumer credit directive and in BNPL regulation. If you want to lend at scale, see setting up a finance company.