BNPL 2026 – credit check in Shopify checkout, responsibility matrix & supplier certificate | Word/PDF/Excel

Does your online store offer invoice, installment, or buy now, pay later (BNPL) at Shopify checkout? The new Consumer Credit Act (2026:1011) comes into effect on 20 November 2026. Businesses need to know what credit they actually offer or facilitate, who the legal lender is, who performs the credit assessment, and what information consumers receive at the actual point of payment. This niche document package helps you conduct exactly that review with a practical evidence- and action-based workflow.

Important: Not every Shopify store offering invoices is a credit intermediary subject to authorization. The legislation distinguishes, among other things, between the seller's own special invoice credit and credit provided by an external BNPL provider. The Swedish Financial Supervisory Authority also emphasizes that whether a business is a credit intermediary under the Consumer Credit Act depends on whether it receives compensation from the lender. Therefore, the templates do not provide automatic answers about authorization requirements or whether a credit assessment is required in a given case.

Digital template package: 5 editable Swedish working templates, 1 Swedish user guide, 1 separate English User Guide – all in Word (DOCX) and searchable A4 PDF – plus an Excel register with 9 tabs and 810 administrative formulas. 7 DOCX + 7 PDF + 1 XLSX = 15 customer files delivered in a ZIP. The PDFs are searchable and printable but not interactively fillable.

Who needs these templates?

Shopify merchants, e-commerce managers, web agencies managing customer checkouts, finance managers, and stores that combine their own invoice terms with an external BNPL/installment solution. The package is particularly relevant if you need to verify who is responsible for the payment widget, lender information, and the actual customer flow ahead of 20 November 2026.

Not automatically covered: standard card payments, Swish without credit elements, all B2B payments, or all invoices. Exact roles, credit type, payment deadlines, costs, and business size determine coverage. This is not a consumer credit agreement, an FI authorization, a loan assessment engine, or a substitute for the bank's credit assessment.

Complete file list – 15 customer files

Difference between formats: 7 Word documents and 7 PDF versions are the same seven documents in two formats. English refers to the separate English guide, not fully translated Swedish working templates. The PDF files are not digital fillable forms.

Excel: nine tabs and 810 real formulas

Read me, Overview, Payment methods, Roles, Checkout test, Suppliers, Customer info, Actions, Sources. The table can flag, for example, “CHECK PAYMENT METHOD”, “INVESTIGATE INTERMEDIATION”, “REVIEW DEFAULT CREDIT”, “AWAIT SUPPLIER RESPONSE”, “COMPLETE INFORMATION” and “MANUAL ATTESTATION REQUIRED”. These are administrative follow-ups, not a legal approval. All 24 scenario tests have passed expected status responses. The customer file is free of test cases, personal identity numbers, and card details; there is no VBA/macro or bank connection.

How to use with Shopify checkout – step by step

1. List the payment methods. Document exactly which invoice, installment, and card options the store displays. Separate the seller's own invoice from an external lender.
2. Assess the scope of the law. Read Chapter 1, Section 3, Chapters 2–5 of SFS 2026:1011 and the exemptions for special invoice credit. Determine whether the store actually facilitates credit for compensation under the relevant Consumer Credit Act definition.
3. Obtain the supplier's statement. Ask the correct lender to state in writing who is responsible for credit decisions, customer information, credit costs, the checkout widget, and any changes.
4. Test the payment flow. Take real screenshots in the supplier's approved test mode on mobile/desktop: defaults, information, and consent. Do not enter personal identity numbers, real credit applications, or customer data into the templates.
5. Correct and attest. Record open deficiencies in Excel. After the supplier or store developer takes action, perform a new test and have the responsible person approve it manually.

Legal boundaries that must not be simplified

SFS 2026:1011 from 20 November 2026: replaces the Consumer Credit Act (2010:1846), with transitional provisions for older agreements. The new law does not apply in exactly the same way to all types of credit. Read the enacted law text.

Special invoice credit under Chapter 1, Section 3: the seller's own credit without credit costs, normally with repayment within 50 days. For a larger seller's distance agreement concluded online, terms of no more than 14 days apply instead, and the credit claim may not be transferred during the term. The special exemptions in Chapter 2, Section 9, Chapter 3, Section 19, Chapter 4, Section 21, and Chapter 5, Section 7 apply only when the entire definition is actually met; external BNPL is not automatically exempt. It is therefore incorrect to claim that all invoice solutions must be subject to credit assessment in exactly the same way.

Defaults and credit information: The Swedish Consumer Agency states that credit options should not be preselected and that credit provision is more strictly regulated. Use template 02 for an actual observation, but check which party responsibility and special rules apply in your checkout. Swedish Consumer Agency news 2 November 2026.

Authorization and supervision: The Swedish Financial Supervisory Authority states that a credit intermediary under the Consumer Credit Act definition must receive compensation from the lender for the intermediation. A smaller subsidiary credit intermediary may be subject to supervision by the Swedish Consumer Agency, while some others require an FI authorization. The assessment is influenced by size, credit type, fees, deadlines, and online/physical channel. Some already operating companies subject to authorization may apply by 20 November 2027 at the latest; new ones may need authorization before starting. Swedish Financial Supervisory Authority guidance.

Staff knowledge: The Swedish Consumer Agency describes the Consumer Credit Act and new competence requirements. KOVFS 2026:1 applies within the proper supervisory scope. This product contains review templates, not an individual credit competence certificate.

Frequently asked questions – BNPL and invoices 2026

Does my Shopify store need to apply for a credit intermediary authorization for Klarna or another BNPL?

Not automatically. The intermediary role, compensation from the lender, and other Consumer Credit Act rules must be assessed from your actual agreements. Authorization requirements and supervision may differ between businesses.

Is all standard 30-day invoice credit subject to assessment under the new rules?

Assess who provides the credit, the credit costs, and the defined terms for special invoice credit. SFS 2026:1011 provides special exemptions; an external BNPL solution may need to be assessed separately.

What happens if the credit option is preselected in checkout?

Document actual behavior via template 02 and refer the question to the responsible payment provider and legal representative. The Swedish Consumer Agency describes this as a regulated risk in the new consumer credit rules. The change is not made by the Word or Excel file.

Who is responsible for the credit assessment – the e-commerce merchant or the payment provider?

The actor that is the lender and another that has an actually applicable duty must be determined. Template 03 requests the supplier's written statement; no standard claim is made that all stores should perform a credit assessment themselves.

Do the new rules also apply to old customer agreements before 20 November 2026?

The older Consumer Credit Act continues to apply as a general rule to agreements before the effective date, with special exemptions for certain ongoing credits. Check the transitional provisions of 2026:1011.

Is the product a complete ready-made customer invoice, credit agreement, or legally valid EU fact sheet?

No. It contains review templates and decision support for the e-commerce payment flow. Credit agreements, mandatory standardized information, authorization, and real credit assessment require separate actual solutions.

Can I connect Excel directly to Shopify or a BNPL provider?

No. Excel is an offline working register. There is no Shopify API connection, bank integration, or automatic credit decision technology in the file.

Are all templates in English?

No. Five operational working templates, a Swedish guide, and Excel are in Swedish. A separate English User Guide helps international colleagues use the Swedish files.

Sources and transparent quality assurance

Reviewed sources: SFS 2026:1011; Swedish Financial Supervisory Authority; Swedish Consumer Agency/Consumer Credit Act; Swedish Consumer Agency news 2026-11-02; KOVFS 2026:1; and FFFS 2026:32.

Version 1.0 – AI-assisted legal source check 9 November 2026. The 15 customer files are technically tested with 24 Excel scenarios, 14 searchable A4 pages, and ZIP integrity check. No external lawyer, authority, or lender has approved or certified the templates. The company's actual contract terms and checkout must be reviewed separately. The product is a digital ZIP – no physical product or subscription.