The new rules are based on the revised EU Consumer Credit Directive, or CCD II for short. Many dental and orthodontic practices are therefore wondering whether they can still offer their patients installment plans and what they need to do now.
The short answer is: Yes, installment plans are still possible. The new obligations do not fall on your practice, but on our financing partner as the lender, and Nelly handles the entire process. You can continue working as usual.
The most important points in 30 seconds
- Installment payments will remain possible after November 20, 2026.
- With Nelly, you can offer installment plans without becoming a lender yourself. Our financing partner bears the obligations.
- Your patients select the installment plan online in the patient portal, and the credit check is performed automatically.
- Down payments and saving up before treatment remain possible.
- Do you currently arrange installment plans with patients yourself? Then you should take action by November 20.
What changes with the new Consumer Credit Directive?
The CCD II (Directive (EU) 2023/2225) is intended to provide better protection for consumers regarding financing. The requirements themselves are not new: they have long applied to traditional, larger consumer loans. What is new is that they will now also cover many smaller financing options, such as interest-free installment plans and short payment deferrals, which were previously largely exempt.
Whether an installment plan is interest-bearing or interest-free primarily determines the extent of the lender's obligations. For interest-bearing installment plans, for example, additional requirements for advertising apply. For Nelly practices, this distinction makes no difference in day-to-day operations because our financing partner assumes the obligations in both cases.
The new rules are legally mandated and apply to all providers of installment plans, as well as to practices that grant installments to their patients themselves.
Who bears the responsibility?
The obligations fall on the lender, i.e., the party granting the financing. At Nelly, this is our financing partner, a factoring institute supervised by BaFin. They are specifically responsible for:
- creditworthiness assessments
- the legally required information and disclosures for your patients
- the mandatory disclosures for financing advertisements
- clear processes for patients experiencing payment difficulties
Nelly implements the entire process for you. Your practice continues to be the only party to the treatment contract. You do not need to register or prepare any credit documentation.
Offer installment payments without becoming a lender yourself
That is exactly what Nelly enables you to do. Your practice remains what it is: a healthcare provider, not a lender.
And your patients?
For your patients, installment payments remain straightforward. They select them directly online in the Nelly patient portal, with no paper forms required. The legally required credit check is triggered automatically, and the result is sent directly to your practice management system. Nothing changes for your front desk team.
What you need to do as a Nelly practice
Almost nothing. We will update the documents and processes and send you updated marketing materials well before November 20, 2026. This also includes coordinated phrasing that your team can use to confidently answer patient questions about installment payments.
Our only request: Please use our materials for any mention of installment payments instead of your own promotional materials. This applies not only to flyers, but also to mentions on your practice website, notices in the waiting room, or conversation guides for your team.
Do you handle your own private billing? Then this change affects you directly
Many practices handle their own private billing and accommodate patients with larger amounts, for example through installment agreements or deferred payment deadlines. The CCD II will cover exactly these types of arrangements in the future. Anyone who grants installments or defers payments after or in connection with treatment may become a lender themselves. The practice would then be responsible for credit checks, mandatory disclosures, withdrawal instructions, and advertising requirements. Down payments and savings plans made before treatment remain unaffected.
Setting up your own legally compliant installment model is hardly feasible for most practices with a reasonable amount of effort. It is easier to hand over billing and installment payments to Nelly. This allows you to continue offering your patients installment payments without becoming a lender yourself, and you receive your fees promptly without having to provide credit.
Use the time until November 20, 2026, to review your current agreements with patients. In a brief consultation, we will show you how switching to Nelly works.
How Nelly supports your practice: We take care of everything
With Nelly you can offer your patients installment plans without becoming a lender yourself. Nelly handles the entire process, from selection in the patient portal and automated credit checks to providing materials for your practice. You receive your fees promptly, without having to provide any advance funding.
Patient financing via Nelly has been structured as a regulated consumer credit product from the very beginning. The new regulations therefore only require adjustments to existing documents, which are already underway.
Do you have questions about offering installment plans in your practice?
Whether you are already working with Nelly or currently handle your own billing: In our free 15-minute CCD-II check, we will look together at what November 20th means for your practice. Book an appointment now
Please note that this guidance has been prepared for informational purposes only, is not legally binding, and does not constitute legal advice. It provides a general overview of the legal situation as of November 20, 2026, and does not replace an assessment of individual cases. For specific questions regarding your practice, please consult your legal advisor.
