BNPL & Invoicing in E-commerce 2026 – Checkout Test, Credit Information and Liability | Word/PDF/Excel

Review invoices, installment payments, and “buy now, pay later” (BNPL) in a Swedish online store. This document package helps e-commerce businesses map out lenders and payment service providers, test payment options, review credit information, and document remedial actions ahead of the new consumer credit act on 20 November 2026. It is not a credit agreement, an official form, or a completed compliance certificate.

Quick facts: Swedish law and EU background; five Swedish working documents, one Swedish guide, and one English user guide. 7 editable DOCX + 7 corresponding searchable PDFs + 1 XLSX, totaling 15 customer files. The PDF versions are for reading and printing, not interactive fillable forms. The Excel file has ten worksheets. The delivery format is a digital ZIP file after publication and separate activation.

Who is the template suitable for—and who is it not suitable for?

For a small Shopify store with an external invoice service, it can help map out how the supplier and the store share actual information and responsibilities. For a larger online store with installment payment campaigns, it helps review the checkout, ads, and supplier responses. However, it is not sufficient for a lender that needs comprehensive credit assessment procedures, statutory consumer information, or a formal license application.

Exact file list

What Excel does in practice

The workbook’s ten tabs are Payment methods, Actors, Checkout test, Marketing, Pre-information, Deviations, Decisions, Role assessment, Start, and Sources and guide. It has ID fields, manual status selections, and an overview with tested formulas that summarize actual register entries. A completed checkout test, a registered credit agreement, or a status of “Approved internally” does not mean that the legal requirements are met. The register does not make automatic decisions about credit intermediary status, special invoice credit, or licensing.

Workflow – from payment method to control decision

1. Inventory payment methods and identify the lender, any credit intermediary, and the payment service provider.
2. Test relevant exemptions based on actual credit terms, compensation, and the size of the store; mark unclear questions.
3. Test in a secure environment how credit options are displayed and whether anything is set as the default in the checkout.
4. Review actual credit messaging, costs, representative examples, and pre-information where required.
5. Collect supplier confirmations, correct deficiencies, and save version-controlled evidence.
6. Make a manual decision with clear reservations and follow-up.

Legal rules and important exemptions

The enacted consumer credit act (2026:1011) will come into effect on 20 November 2026. It regulates marketing, information, and credit assessment, among other things. Special invoice credit requires several cumulative conditions regarding who provides the credit, the cost, and the repayment period. Exemptions apply only to specifically stated provisions. For larger sellers who enter into distance agreements online, a stricter 14-day limit and requirements regarding the transfer of the claim also apply. An external BNPL service is therefore not automatically exempt.

According to the Swedish Financial Supervisory Authority’s guidance, a company’s classification as a subsidiary lender/intermediary depends on factors including its actual business activities, any facilitation compensation, and agreements. The competent supervisory authority and any licensing requirements must be assessed separately. The Swedish Consumer Agency’s guidance also covers the order and default settings of payment options under the payment services act. Do not use the template to determine who is responsible without an agreement and verified legal assessment.

Compare with other documents

B2B Credit Policy applies to credit limits and credit risk between businesses, not the consumer’s BNPL checkout. The Accessibility Act for E-commerce is another control track for the customers’ digital purchasing experience.

Frequently asked questions

Is a store with an external invoice solution automatically a credit intermediary?

No. This must be determined from actual activities, compensation arrangements, and relevant legal definitions.

Are all interest-free invoice purchases exempt?

No. “Special invoice credit” has express cumulative conditions, and exemptions cover only certain provisions.

Can an online store have a credit option set as the default?

The rules on the presentation of payment options must be assessed under the payment services act and the actual design of the checkout; the responsible payment service provider must be involved.

Are the PDF files fillable, and are all files bilingual?

No. Edit the DOCX. The PDFs are searchable/printable without interactive forms. The working templates and Excel file are in Swedish; only the separate User Guide is in English.

Is the package a completed legal compliance?

No. It structures the documentation work and does not replace licensing, credit assessment, external legal assessment, or your own controls in the actual checkout.

Sources and version

Version 1.0, 9 November 2026. AI-assisted legal source review without external legal review. Check the current rules on the Swedish Consumer Agency’s updated questions and answers, as well as through the Swedish Financial Supervisory Authority and the Swedish Parliament, before use.