Instalments and pay-later in Norway: the credit rules for foreign webshops

Norwegian shoppers expect to be offered an invoice or an instalment plan at checkout. In Norwegian law, both are credit agreements. A foreign webshop that adds these options, or advertises a monthly price, is placing consumer credit in front of Norwegian consumers, and the rules for consumer credit apply.

Pay-later is credit

In February 2025 Forbrukertilsynet, the Norwegian Consumer Authority, sent a guidance letter to businesses offering “buy now, pay later” services. The letter states that many of them operate in breach of the law by offering these services without meeting the requirements for credit agreements in the Financial Agreements Act (finansavtaleloven).

The reasoning is short. A deferral of payment is a credit agreement under section 1-7 of the Act. A pay-later service typically defers payment by 14 or 30 days. It is therefore a credit agreement, and the mandatory rules for credit agreements in chapter 5 apply, together with the general rules for financial services in chapter 3. An instalment plan over several months is a credit agreement on any reading.

The rules cannot be varied by contract to the consumer’s detriment (section 1-9). Terms written for another market do not displace them.

The single exemption

Section 5-22, first paragraph, letter e, exempts a deferral of payment from chapter 5 when all of the following conditions are met:

• the deferral is granted by the seller of the goods or service;
• it is free of charge, or the cost to the customer is insignificant;
• the credit is not intended to exceed 90 days;
• the seller’s claim is not transferred to anyone else before it falls due.

The exemption corresponds to buying “on account” at a local shop. It does not cover the arrangements most webshops use. Where a payment company provides the financing in cooperation with the seller, the Authority’s position is that the service is a credit agreement. The preparatory works give the reason directly: a consumer who chooses credit from a payment intermediary should not have weaker protection than a consumer who pays by credit card. Even where the exemption applies, the chapter 3 rules on financial services still do.

Provider and merchant

Most of the statutory duties fall on the provider of the credit, which is usually the payment company and not the webshop. The provider must:

• give pre-contractual information, including costs, payment arrangements and the standardised European consumer credit form;
• explain the main features of the agreement and the consequences of non-payment (section 5-1);
• assess the consumer’s creditworthiness before entering into the agreement (section 5-2);
• refuse the credit if the consumer is unlikely to be able to repay on the terms offered (section 5-4);
• conclude the agreement in writing, with secure authentication and the consumer’s signature, in practice by BankID;
• provide the 14-day right of withdrawal from the credit agreement (section 3-41) and a written complaints procedure.

The merchant’s exposure lies in marketing. Section 3-3 of the Act requires the marketing of financial agreements to comply with the Marketing Control Act, and the Financial Agreements Regulation (finansavtaleforskriften) sets specific rules for marketing credit agreements to consumers in sections 3-2 to 3-5. Those sections are written for the provider of the credit. A webshop that displays a monthly instalment price on a product page is promoting that provider’s credit agreement, and the prudent assumption is that its marketing will be measured against the same rules.

What an instalment price must state

Under section 3-4 of the Regulation, any marketing of a credit agreement must contain the following information:

The information must be given clearly by means of a representative example, and the same example must be used consistently throughout the marketing. A banner that reads “from NOK 299 a month” and nothing else does not meet the requirement.

Section 3-3 adds a rule on add-on benefits. Where a credit offer comes with a bonus, discount or other extra, the extra may not be given a more prominent place than the information required by section 3-4.

What it may not emphasise

Section 3-5 of the Regulation prohibits emphasising any of the following in the marketing of a credit agreement:

• how quickly the credit can be used;
• how quickly a reply to a credit request can be expected;
• that the threshold for obtaining credit is low;
• that the application process is simple;
• that the credit is easily available in other ways;
• an interest rate other than the effective rate, more prominently than the effective rate;

These points may still be mentioned as part of the application process or the credit terms, provided they are given no more prominence than the section 3-4 information. Section 3-2 prohibits marketing credit agreements through door-to-door selling.

Copy that is ordinary in other markets, such as “approved in seconds” or “split your payment, no hassle” beside the instalment option, is the category of wording the section addresses.

Cost to the buyer

The rules exist because these plans can be expensive, and Norwegian consumer guides now set the published examples out in full. Komplett, a large Norwegian electronics retailer, publishes the terms of its instalment plan from Walley: a set-up fee, a monthly interest rate and a monthly fee. Its own example is a purchase of NOK 11,999 (about $1,300) repaid over 36 months, at an effective annual rate of 36.73 per cent, for a total of NOK 18,560 (about $2,000).

Fixed monthly fees weigh most on small purchases. A Norwegian guide to what delbetaling costs (in Norwegian) works through Klarna’s and Walley’s published examples and shows the effective rate rising above 100 per cent on a small purchase on the same terms. That is the comparison a Norwegian customer is able to make, and it is the reason the regulator requires the effective rate and the total to stand beside any monthly price.

Credit checks and the debt register

Because the provider must assess creditworthiness and must refuse credit where repayment is unlikely, a share of customers will be declined at the instalment step. The Authority’s guidance gives the scale: a 14-day deferral of NOK 499 will rarely require a refusal, while several months’ deferral of NOK 4,999 may, particularly for a consumer without a fixed income or with high debt.

Instalment credit is also visible to Norwegian lenders. Klarna states on its Norwegian site that it reports outstanding debt and credit limits to the national debt register. A customer applying for a mortgage or car loan will find that credit counted. For both reasons, a Norwegian checkout should keep a payment route that does not involve credit.

Claims against the provider

Section 2-7 of the Act allows a consumer who has a claim against the seller to raise the same objections against a credit provider other than the seller, where the credit is granted under an agreement between the seller and the provider. That describes an instalment plan offered at checkout.

In practice, a complaint about faulty goods that the webshop leaves unanswered can be raised with the credit provider, and the provider will look to the webshop under its merchant agreement. The provider must inform the consumer of these conditions before the agreement is concluded (section 3-34).

Enforcement

The guidance letter states that the Authority will consider inspections of individual businesses offering pay-later services, and that the fact guidance has now been given will be taken into account when it assesses breaches and sanctions. Businesses are expected to have read it. Marketing of financial agreements is also subject to the Marketing Control Act, which the Authority enforces with orders, coercive fines and infringement penalties.

Checklist

The same review applies to the rest of a Norwegian storefront. Reference prices in campaigns are covered by Norway’s sale price rules, and payment methods, delivery and pricing in kroner by selling into Norway from abroad.

Sources

• Forbrukertilsynet, veiledning om lovkrav ved tilbud av tjenester som innebærer “kjøp nå, betal senere” (3 February 2025) for the classification as credit, the exemption and the provider’s duties.
• Lovdata, lov om finansavtaler (finansavtaleloven) for sections 1-7, 1-9, 2-7, 3-3, 3-34, 3-41, 5-1, 5-2, 5-4 and 5-22.
• Lovdata, forskrift om finansavtaler (finansavtaleforskriften) for the marketing rules in sections 3-1 to 3-5.
• Klarna, betalingsmetoder for reporting to the debt register.
• Komplett, delbetaling for the Walley instalment terms and price example.