BNPL promotion rules 101

Klarna offers one "Buy Now Pay Later" (“BNPL”) products in Ireland:

- Pay in 3 instalments, defined as “BNPL product(s)” throughout this document.

This guide is only for Klarna merchants. It covers how merchants should advertise BNPL products to consumers in Ireland. The Advertising Standards Authority for Ireland is Ireland’s independent regulator of advertising, and it makes sure that everyone follows the advertising codes. 

Being legal, decent, honest and truthful and not misleading the consumer is important. Many merchants have shared with us what works for them and combined with our expertise, we’ve come up with some best practices outlined in this guide. The advertising guidelines have been designed to provide direction on what you can and can’t do but should not be seen as a substitute for legal review of marketing material.

• Always include a disclosure.
• Always include a risk warning (inc. eligibility criteria). Risk warnings should not be less prominent than the potential benefits of the product/service. 
• Use our short form disclosure if there is genuinely limited space.
• Always provide a link to our terms and conditions www.klarna.com/ie/terms-and-conditions
• Making it clear. All advertisements should be legal, decent, honest and truthful. All advertisements of financial products should be presented in a way that can be easily understood and must not take advantage of consumers' inexperience.

Each communication (whether it be a homepage banner, an email, a tweet or an Instagram post for example) needs to follow the rules, including being legal, decent, honest and truthful and not misleading the consumer.

The Advertising Standards Authority of Ireland  (“ASAI”) is Ireland’s advertising regulator and responsible for applying the Manual of Advertising Self-Regulation with the Code of Standards for Advertising, Promotional and Direct Marketing in Ireland. These apply to all Irish firms.

The ASAI considers all complaints about non-technical aspects of advertisements in non-broadcast media. For example, offence, social responsibility, fear and distress and competitor denigration. The ASAI also assesses complaints about broadcast advertisements. The ASAI investigates general advertising complaints and can:

• Require changes to advertising or ban advertising
• Publish findings and decisions on the ASAI website
• Refer a complaint to National Standards Authority of Ireland (NSAI), who have a broader range of enforcement powers available to them. NSAI can, for example, take legal action resulting in possible (unlimited) fines and/or imprisonment

ASAI general rules

Relevant principles:

• Marketing communications in the media and sales promotions should be legal, decent, honest and truthful and should not mislead the consumer.
• Primary responsibility for observing the Code rests with advertisers, promoters and direct marketers.
• Marketing communications should be prepared with a sense of responsibility to consumers and to society.

Consumer Credit Act 1995 advertising requirements

• The APR. The display of any other rate of interest is not allowed. The APR must be as prominent as any other figure shown (i.e. 0% APR).
• The period over which payments are required.
• The total cost of credit.
• Details of the deposit required (or confirmation that none is required). 
• Whether the required payments are payable monthly, bi-monthly etc.
• The total number of payments required.
• Details of any other payments required (i.e. Arrangement fee/documents fee)
• An indication of any restriction that applies to the availability of credit.

Klarna offers one BNPL product in Ireland: 

Pay in 3 instalments allows a consumer to spread the cost over 3 equal payments. This product is completely interest-free and there are no late fees. 

These BNPL product advertising guidelines tell you what to do when advertising Klarna’s Pay in 3 instalments credit product defined as  “BNPL products” throughout. Remember that it is also your responsibility to learn and understand the laws governing the advertising of unregulated financial products.

• All Partner marketers who are responsible for Irish marketing initiatives for BNPL products;
• Partner legal and compliance teams; and
• Marketers looking for guidance on Klarna Irish marketing compliance for BNPL products.
• Any other interested or relevant individuals within our partners.
• BNPL Product Promotions, disclosures, risk warnings and messaging.
• Outlined below are some pre-approved examples of what you can and must do in respect of BNPL product promotions, disclosures and messaging when advertising BNPL products.

What is a disclosure? 

A disclosure is required to be added on most BNPL product promotions so that consumers understand the nature and features of the BNPL product they are using. 

What is a risk warning?

A risk warning forms part of the disclosure and should be presented closely together with any benefits being promoted. Risk warnings highlight the possible negative consequences of a purchase or (mis)use of a product and provide information that ideally helps a potential customer to weigh up whether the product is suitable for them.

For example, the risk warning in our disclosure is this part: “Missed payments may affect your ability to use Klarna in the future”.

A BNPL product promotion is a prompt or encouragement to use a BNPL product.

Examples where a disclosure is not required

There are some specific pre-approved examples that you can use in your BNPL product promotions that do not require disclosure. These may be included in the BNPL product promotion and/or accompanying body copy in social media, for example.

If you choose to only use these three options listed above, you do not need to add the disclosures and risk warnings outlined on the following pages.

You must not “bundle” financial promotions which refer to Klarna BNPL products with other BNPL products and providers, for example:

In our view, “bundling” financial promotions contravenes the ASAI’s overarching principle of being “legal, decent, honest and truthful”. Since our terms differ significantly from other BNPL products provided by different providers, i.e. we do not charge any late fees and have monthly repayment schedules rather than fortnightly, financial promotions “bundling” should not take place. Klarna does not support this type of marketing.

Below we have provided the appropriate disclosure for a selection of common marketing channels in which you might promote Klarna and its products. Please copy and paste the text of the relevant disclosure onto the relevant marketing communication.

Important: if you cannot provide a link in your bio for T&Cs then use the full URL in your post www.klarna.com/ie/terms-and-conditions

Important: if you cannot provide a link then use the full URL in your post www.klarna.com/ie/terms-and-conditions

Limited space disclosure

Quick checklist for BNPL product promotions:

• Update onsite messaging incl. banners with approved Klarna messaging.
• The landing page is up-to-date - A reminder that it is mandatory for the Klarna landing page to be visible and easily accessible within the navigation of your website.
• FAQs page are up-to-date - A reminder that it is mandatory for the Klarna FAQs to be visible and easily accessible within the navigation of your website.
• Email/CRM - BNPL disclosures are included at the bottom of emails when talking about Klarna’s BNPL products.
• BNPL disclosures updated for all channels in use (TV, billboard (print or digital), website, radio or podcast & social media).
• Klarna T&Cs are one click away (where possible) from the point of communication for all channels in use. 

If yes, GOOD TO GO.

If you choose to use these options these are BNPL product Promotions and therefore require disclosures and risk warnings outlined below. As well as using the pre-approved risk warning you must also accompany your BNPL product promotion with a link to the Klarna terms and conditions page or to your dedicated Klarna frequently asked questions page that includes Klarna’s terms and conditions and a pre-approved disclosure.

When referencing Klarna products, it’s important to use the appropriate disclosure. Disclosures and risk warnings must be prominent, clear, and placed on the BNPL product promotion itself. The risk warning itself must be prominent and should not be given less prominence than the potential benefits of the BNPL product being promoted.

Select from the pre-approved messaging and appropriate disclosure from below to include in your advertisement:

Build a dedicated landing page to educate your shoppers about Klarna and the different payment options at checkout. You can help increase trust and conversion rates by proactively addressing customer questions or concerns.

You can simply copy and paste all content needed for the landing page about Klarna from below. Make sure to use the provided text so as to avoid misinterpretation of terms. Please note this copy only applies to Pay in 30 days and Pay in 3 installments. If you are offering our financing product, please speak to your Klarna point of contact for guidance.

Best practice:

Include links to What is Klarna and Klarna’s Customer Service to make the shopping experience even better.

We got it covered - we answered frequently asked questions that your customers may have about Klarna before, during or after the purchase. Just choose the Klarna product FAQ below, copy the relevant questions to your site, insert your online store name and applicable terms in the areas in brackets. And done! Please note: if you're offering our financing product, please speak to your Klarna point of contact for customer FAQ.