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BNPL and credit apps: what the new Czech law changes on screen
The Czech credit bill brings more BNPL and free credit into scope from February 2027. Which app screens change, and what must ship before January.
Zdeněk Dolák · Founder9 min read
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Czech lending and buy-now-pay-later apps have two dates to plan around, and neither is the 20 November on every EU summary of the new consumer credit rules. From 1 January 2027, an online interface used to sell financial services must not manipulate the customer. From 1 February 2027, if the bill is signed, the amended consumer credit law applies: more BNPL and interest-free credit comes under it, consumer loans get a price cap, and the customer journey in a lending app changes in ten places.
The authorisation has a transition. The screens do not. A firm already offering free credit before 1 February can continue on its existing authorisation for up to 16 months, and until ČNB decides if it applies in that time. Nothing in the transition delays the customer-facing rules, and staff competence requirements still apply. A firm that starts on or after 1 February gets no transition.
This article separates the dates, shows who comes into scope, walks through the changes moment by moment, and looks at the price cap, where Apple is stricter than Czech law. It reads the text approved by Parliament. The Senate passed the bill on 21 October and it reached the President on 27 October, with a decision due by 11 November. It had not been signed or published when we checked on 1 November 2026. The examples are fictional.
The dates
Scroll sideways to see every column.
| Date | What happens | Who it touches |
|---|---|---|
| 20 November 2026 | The EU Consumer Credit Directive (2023/2225) applies. Czechia misses this date. Slovakia's law takes effect on it. | Anyone lending in another EU country: check that country's law. |
| 1 January 2027 | Czech law 159/2026 Sb. bans manipulative interfaces when financial services are sold at a distance, and adds a withdrawal button to the Civil Code. | Financial services sold online. For consumer credit, the approved bill applies the button expressly from 1 February. Ask your lawyer about credit agreed in January. |
| 1 February 2027 | The amended consumer credit law takes effect. | New consumer credit agreements, and some rules for existing open-ended credit. |
| 1 June 2028 | The last day of the 16 months in which firms can apply for authorisation or be notified as an agent. | Firms offering free credit before 1 February 2027 without the authorisation the new law requires. |
Between now and 1 February
On the approved text, credit agreed before 1 February 2027 stays under the current Czech law, with exceptions for open-ended credit. The directive is addressed to Member States. Whether the missed date has any effect on a Czech lender, including how a court would read current law, is a question for your lawyer.
Free credit needs a separate check. A transitional provision (Art. II, point 13) applies the new text to it from 1 February without saying only new agreements, so ask your lawyer about existing free agreements.
Four things matter in this period:
- From 1 January, the interface rule applies.
- The repo rate on 1 January sets the price cap for the first half of 2027.
- Only a firm offering free credit before 1 February can use the authorisation transition.
- A contract agreed on or after 1 February falls under the new text even if the application started in January, so decide how to handle applications in progress.
Until then the current standard form remains the required one, so do not switch early.
Who comes into scope
Today, credit with no interest and no charges sits almost entirely outside the Czech law. The bill removes that exception. For a purchase, what remains is narrow: a seller's own deferred payment, with no interest or charges, due within 50 days of delivery. For online sales by a company larger than an SME, the limit is 14 days from delivery, and neither the agreement nor the claim may be assigned to a third party.
So the question is no longer only "do we charge anything?" It is also who gives the credit, how long it runs, and how large the seller is.
Illustrative cases. Check your own product with your lawyer.
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| Product | On the approved text | Why |
|---|---|---|
| BNPL from a separate provider at checkout, free, pay in 30 days | In scope | The credit does not come from the seller. |
| Interest-free instalments through a finance partner | In scope | The same reason, and the term is usually longer. |
| A small e-shop's own invoice, free, due 30 days after delivery | Mostly outside the law | Seller's own credit, free, within 50 days of delivery, and the seller is an SME. A few sections still apply. |
| A large online retailer's own invoice, free, due 30 days after delivery | In scope | Above the 14-day limit for companies larger than an SME. |
| A large online retailer's own invoice, free, due 14 days after delivery, claims sold to a factoring company | In scope | The claim passes to a third party. |
| A seller's own interest-free instalments over six months | In scope, with defined credit-check sources within the wage limit | Above 50 days, but see below. |
Free credit in scope gets two reliefs:
- Less to disclose. Some items in cost advertising, the longer part of the pre-contract information and one contract item do not apply. The advertising warning and the core pre-contract information do. A badge that says 0 % may still count as a cost figure, which could bring the rate, the APR and the credit amount back into the advert, so ask your lawyer.
- Defined credit-check sources. For a seller's own free deferred payment up to the average national wage, a defined set of sources is enough, used together: the employer reporting system where available, payment account and transaction data, and a credit database. For a retailer that checks nothing today, this is still new work. The bans on special-category and social network data still apply.
A retailer that only places someone else's BNPL at checkout should also check whether that makes it a credit intermediary.
Ten moments that change in the app
The table follows the journey from the first promotion to a customer in arrears. It covers consumer credit other than housing loans. The last column gives the section of the amended law, law 257/2016 Sb. unless marked, so your lawyer can check each row.
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| Moment | What the text asks | What it means in the app | Section |
|---|---|---|---|
| Promotions | A clear and prominent warning: „Pozor! Půjčit si peníze stojí peníze“ ("Caution! Borrowing money costs money") or wording with the same meaning. Advertising must not suggest credit improves the customer's finances, or that existing debts barely affect a credit check. | Review banners, push messages, checkout badges and store listings as advertising, unless your lawyer says otherwise. On a small format, some cost details may sit behind a click, scroll or swipe. The warning has no such exception. | § 91, § 77a |
| Personalised offers | Tell the customer when an offer is tailored by automated processing of personal data. | A notice beside the offer, and a flag from the system that made it. If the price was tailored, the pre-contract information says so too. | § 77b, § 95(2)(q) |
| Selecting credit and add-ons | Consent to a credit contract or an add-on chosen from options must be explicit and informed. It cannot be inferred from a pre-set option the customer would have to refuse. | No pre-ticked insurance or payment protection, and no pre-selected pay-later option at checkout. | § 104a |
| Pre-contract information | A new standard form, with the main items first and the rest clearly separated. All items equally prominent, displayed consistently within the device's limits. | The law speaks of a first page and a second page; a phone has neither. Decide with your lawyer how that maps to a scrolling screen. Free credit omits the longer part, so the form differs by product. | § 95, § 99, Annex 2 |
| Durable record | For the forms and notices the law lists, the customer chooses between paper and another durable medium. | A real choice in the flow, stored per customer and reflected in the contract. Check any channel, including an in-app inbox, against the definition of a durable medium in § 3(2)(k) with your lawyer. | § 90(3), § 99(7), § 106 |
| Credit check | No special-category data under GDPR Article 9 and no information from social networks in the assessment. If automated processing is part of the check, tell the customer about the right to human review before the contract is agreed or with the rejection. | Check what the onboarding passes to the assessment, including data from a social sign-in. Add the notice at the right step. | § 86(3), (6) |
| Rejection | If the assessment leads to a refusal, tell the customer without delay and refer them to debt advice where relevant. If a database search was the reason, give the result, the database and the data categories. Say so if an automated result was the reason, and how to ask for review. | The usual "we can't offer you credit" screen is no longer enough. It needs variants driven by the reason. | § 89 |
| Human review | Where automated processing is part of the check, a staff member explains the assessment on request, hears the customer's view, and can review the assessment and the decision. | A request path in the app, and a queue, case history and response in the admin tool. This is staff work with a screen on each end. | § 86(5) |
| Withdrawal | If the information arrives less than a day before the customer commits, send a reminder of the right to withdraw one to seven days after the contract or the customer's binding offer, on the chosen durable medium. Where the contract was concluded online, a prominent button labelled „Odstoupit od smlouvy“ or equivalent wording stays available for the whole period, followed by a confirmation button and a confirmation in text form. | A loan agreed minutes after the form was shown triggers the reminder, so it needs scheduling, and a push alone is unlikely to be enough. The period is not always 14 days, so it cannot be a constant. A contract signed on the web needs the button on the web: the customer should not have to download an app to use it. | § 100a, § 118; Civil Code § 1830a |
| Arrears and difficulty | Refer customers in difficulty to debt advice. Where appropriate, offer a reasonable measure before starting proceedings. Within 30 days of reporting a delay to a credit database, tell the customer which database and what their GDPR rights are. | New messages and a route to changed terms. The contract also carries a debt adviser's contact, which belongs in the app's help. | § 124a, § 124b, § 88(4), § 106 |
One rule covers every screen that leads to the contract. From 1 January 2027, under law 159/2026 Sb., an online interface used to conclude a financial services contract at a distance must not deceive or manipulate the customer or seriously limit a free decision, and that includes giving one option a misleading prominence. A consumer credit agreement counts as a financial service in the EU directive behind that law. A bright "Get the loan" beside a barely visible "No thanks" is the kind of screen to look at first.
Fines under the amended law reach CZK 20 million at the top end, depending on the breach.
The price cap, and where Apple is stricter
For most consumer credit other than housing loans, the annual percentage rate must not exceed four times the sum of the ČNB repo rate and 8 percentage points, with the repo rate counted at no less than 4 %. Tied vehicle credit uses an adjusted measure. The repo rate is 3.75 % as of 1 November 2026. If it is still below 4 % on 1 January 2027, the cap for the first half of 2027 is 48 %. The Ministry of Finance describes the limit as around 50 %.
Small, short credit has its own rule instead. For up to CZK 20,000 and up to 12 months, total cost must not exceed CZK 2,000 plus the amount multiplied by the term and the same rate. In a fictional example, CZK 10,000 for six months at the 48 % rate gives a ceiling of 2,000 + 2,400 = CZK 4,400. A second such loan from the same lender within 12 months loses the CZK 2,000, unless it starts at least a month after the earlier ones were repaid.
Two things follow for an app. The cap moves with the repo rate on the first day of each half-year, so it cannot be a constant in the app's code; the limits have to come from the server. And a lender that breaches the cap loses a lot: interest falls to the repo rate unless a lower rate was agreed, and other agreed charges are disregarded.
The stores set their own limits, and these do not follow Czech law:
- Apple does not allow loan apps with a maximum APR above 36 %, including costs and fees, or that require repayment in full in 60 days or less.
- Google Play does not allow personal loans that require repayment in full in 60 days or less. Its 36 % limit applies to the United States only. Google also asks for the loan terms in the store listing and bars personal loan apps from sensitive data such as contacts or photos.
An illustrative case: a personal loan at 45 % can sit under the Czech cap and still break Apple's rule. The harder question is short BNPL. Google's definition of a personal loan leaves out financing a fixed asset and revolving credit; Apple's guideline does not define the term. We found no published answer on how either store treats a 30-day BNPL product, so ask before you plan the app around it. The article on Apple's EU payment rules covers a separate question: how an app takes money.
Why a mobile app makes the dates harder
A website can change for every visitor at once. An app cannot, and that is the part legal summaries leave out.
- Old versions stay installed. A customer on last month's version will not see a new warning or form unless you force the update or the content comes from the server. Anything that changes how sign-up or checkout steer the customer should ship before 1 January. The credit-law changes ship in January and switch on from the server on 1 February.
- Store review sits in front of you. A release has to pass the stores before customers get it, and a screen about credit may draw questions. Leave time for that before the date, not on it.
- Two rulebooks run at once. Agreements from before 1 February generally stay under the old law, with exceptions for open-ended credit and possibly free credit, so the app must show each contract the information that applies to it. The contract date has to be a field the app can read.
- The app cannot hold this alone. The scoring, the cap and the reasons for a rejection live with the lender. The app shows them, and it can only show what the API returns: a decision reason, the database used, an automated flag, the limits and the form data per contract. The article on what your API needs lists what to ask the backend owner.
What to do before the dates
- Check that the law has been signed and published, and read the final text.
- Review how sign-up and checkout steer the customer, and ship any changes before 1 January.
- Put each product through the scope question with your lawyer: who gives the credit, for how long, at what cost, how large is the seller, and was it on offer before 1 February?
- Ask your lawyer about existing free agreements and applications in progress on 1 February.
- Walk your own journey against the ten moments above and mark what is missing.
- Ask the backend owner what the API returns for each of them, and who changes it if it does not.
- Set a January release date, keep the new rules switched off until 1 February, and decide how customers on older versions will be moved.
- Compare your APR and repayment terms with both stores' rules before you commit to a design.
- If you are newly in scope, plan the authorisation next to the release. ČNB has 12 months to decide on an application made under the transition.
We build the app side of this: the screens, the admin tool and the release. The rules and the scoring stay with you and your lawyer, the decision to lend is yours, and we describe how we work on the mobile app development page. If you want a view on how the journey works as an app, write to us. That is product and engineering input, not a legal review.
This article is general information, not legal advice. It reads a text that had not yet been signed or published on the date below. Compliance belongs to the firm offering the credit, so have your lawyer confirm how each rule applies to your product.
Sources
- Czech Chamber of Deputies: Tisk 145, history of the bill (Senate approval 21 October, delivered to the President 27 October, decision due by 11 November) and the text approved by the Chamber (all section references above, transitional provisions in Art. II, effect in Art. IX)
- Current text of the Czech consumer credit law: Zákon č. 257/2016 Sb. (§ 5(3) today's exception for free credit, § 3(2)(k) durable medium, § 110 consequences, § 118 withdrawal)
- Zákon č. 159/2026 Sb. (Consumer Protection Act § 5e, Civil Code § 1830a, effect 1 January 2027)
- EU: Directive (EU) 2023/2225 (Art. 2 scope, Art. 8 advertising, Art. 18 creditworthiness, Art. 48 dates) and Directive (EU) 2023/2673 (recital 9 on consumer credit as a financial service, recitals on the withdrawal function)
- Slovakia: Zákon č. 312/2025 Z. z. (Art. XII, effect 20 November 2026)
- Czech National Bank: history of the two-week repo rate (3.75 % since 19 June 2026)
- Czech Ministry of Finance: press release on the Chamber's approval (limit around 50 %)
- Apple: App Review Guidelines, 3.2.2(ix), last updated 16 October 2026
- Google: Play Console Help, Financial Services policy (personal loans)
All sources were checked on 1 November 2026.
Zdeněk DolákFounder of Tolaron. Spent the years before it building payment software.