Klarna Docs - BNPL promotion rules 101

Unauthorised Partners (i.e. Partners that are not authorised by the FCA) that communicate Financial Promotions without approval by Klarna are at risk of committing a criminal offence. Learn more.

Only pre-approved downloaded assets or Klarna On Site Messaging will be deemed approved by Klarna.  If you amend any wording or use your own bespoke assets, your promotion does not have Klarna’s approval and you will be required to remove or update non-compliant Financial Promotions in order to avoid:

1) breaching your contractual obligations with Klarna; and

2) committing a criminal offence.

Partners that do not take the action requested to remedy a non-compliant Financial Promotion may have their payouts terminated and Klarna reserve's its right to terminate its contract with you.

Extra rules apply when you advertise Klarna’s longer term Regulated Financing options. If you offer Klarna’s regulated financing, you must use the Regulated Financing Guidelines

Partner marketing that does not comply with these rules will not be approved by Klarna.
Klarna offers two different Buy Now Pay Later credit products in the UK (BNPL products): 

  • Pay in 3 instalments allows a consumer to spread the cost over 3 equal payments. This product is completely interest-free. 
  • Pay in 30 days allows a consumer to get up to 30 days to pay for their goods with no interest.

When advertising Klarna's BNPL products you MUST follow the following Rules for your advert to be compliant with the laws around advertising credit in the UK, and therefore approved by Klarna. If you amend any wording or do not follow our Financial Promotions Rules, your promotion will not be approved by Klarna’s. These rules must be followed by all Partners who market our BNPL products in the UK.

Remember that if you are not authorised by the FCA you are at risk of breaching the Financial Promotion Restriction if you communicate Financial Promotions without approval. Learn more.

The most important rule you need to know is this: Invitations to credit always trigger the requirement to add the UK BNPL Disclosure.

Why do I need a disclosure on my marketing?
Whilst the BNPL product remains unregulated in the UK, the advertising of them is subject to the Financial Conduct Authority’s regulatory requirements. At the centre of these is the need to ensure communications about BNPL give customers everything they need to know before they decided to use credit to make their purchase. Partners must ensure adverts are balanced and do not emphasises the potential benefits of a product or service without also giving fair and prominent indication of any relevant risks.

What is a disclosure? 
A disclosure is required to be added on 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:

Borrowing more than you can afford or paying late may negatively impact your financial status and ability to obtain credit.

Klarna's BNPL disclosure

To deal with these requirements, and to ensure customers understand the product, it is essential that any advertising that is promoting BNPL products includes the UK BNPL Disclosure. The disclosure is designed to provide key information to the customer about the product as well as the all important risk warnings

In any marketing it is important to always be clear with customers. This however becomes especially important in relation to the BNPL disclosure.  You must ensure that the UK BNPL disclosure is prominent enough to meet the FCA's requirements. 

This means:
1.  In relation to the other content of the marketing asset;
2. The disclosure is prominent enough (in time shown, size, clarity and colour);
3. In such a way that is likely that the attention of the average consumer would be drawn to it.

The most important things to remember are:

  • SIZE (your disclosure size should be at least 50% the size of the invitation to credit / promotion of BNPL)
  • COLOUR (your font colour should be WHITE if the background is dark, or BLACK if the background is light)
  • VISIBILITY (your disclosure must not be laid over busy imagery / pattern / other markings that makes the text less visible)
  • PLACEMENT (your disclosure should be placed WITH the invitation to credit / other promotion and as a general rule should always be visible on the same screen without the need to scroll).

READ TIME (for video content, the disclosure must be on the screen for a minimum of 8 seconds to enable it to be readable)

Prominence rules:

SIZE at least 50% + COLOUR (white on dark) OR (black on light) + VISIBLE + PLACED with Invitation to Credit = MAY BE APPROVED
(You are ready to submit your bespoke asset for approval by Klarna)

An invitation to credit prompts or encourages a consumer to use a BNPL product. 

The UK law does not define the term "invitation" but they are interpreted widely. The UK regulator’s view is that "the expressions 'invitation' or 'inducement'suggests any communications which have a promotional element.."

Due to the wide interpretation of ‘invitation to credit’, it is important to consider whether the overall impact of your advertising is to promote a BNPL product. If it is, you will need to observe these RULES for advertising BNPL.

No disclosure:

If you use one of the three PRE-APPROVED prompts below, it is not a Financial Promotion and no disclosure is required:

  • “Klarna available”.
  • “Klarna available at checkout”; or
  • [Klarna logo]

Disclosure required:

Below is a list of PRE-APPROVED invitations to credit that will trigger the need to add the BNPL disclosure.

  • “Get more time to pay with Klarna”
  • “Pay in 3 with Klarna”
  • “Split your purchases into 3 interest-free payments”
  • “Shop now. Pay in 30 days with Klarna”.
  • “Shop now. Pay over time with Klarna”
  • “Shop now. Pay with Klarna.”
  • “Flex your payments.”
  • “Pay Instore with Klarna”.

If you choose to use these options these are "Invitations to Credit" prompts and therefore require the disclosures and risk warnings outlined below. As well as using the pre-approved disclosure 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.

APPROVED PROMPT + PROMINENT DISCLOSURE / NO INVITATION TO CREDIT + T&CS OR FAQS = MAY BE APPROVED
(You are ready to submit your bespoke asset for approval by Klarna)

AMENDED WORDING or NO DISCLOSURE or NOT FOLLOWING THESE RULES = WILL NOT APPROVED

(You must amend your marketing before submitting it for Klarna approval)

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

Shop Now, Pay Later with Klarna, AnotherPay & More = WILL NOT BE APPROVED

Bundling financial promotions contravenes the FCA's overarching principle of being “clear, fair and not misleading”. Since our terms differ significantly from other BNPL products provided by different providers, i.e. we have monthly repayment schedules rather than fortnightly, financial promotions “bundling” should not take place. This type of marketing will not be approved by Klarna.

  • Disclosures should be positioned horizontally.
  • Full terms and conditions should be no more than one click away. 
  • Risk warnings should not be less prominent than any wording about the potential benefits of the product.
  • Always provide a link to our terms and conditions or display the full URL klarna.com/uk/terms-and-conditions

Social media disclosure placement tips

  • Instagram feed - Include in the image or in text. Not buried within or under multiple hashtags. If you cannot provide a link in your bio for T&Cs then use the full URL in your post: klarna.com/uk/terms-and-conditions.
  • Instagram stories - Include disclosure in images.
  • Twitter - Avoid placing disclosures in an image.
  • Google ad - Disclosure can be at the end of text.
  • Banners - Dynamic/carousel banners may include disclosure in the final frame. 
  • Email CRM - Include the disclosure / risk warning next to the invitation to credit or any wording about the potential benefits.

Below we have provided the appropriate disclaimer for a selection of common marketing channels in which you might promote Klarna and its products. Please copy the text, replacing the elements in bold which apply to your company and the Klarna products featured in the promotion. Remember, if you are using Klarna Brand BNPL Messaging with no specific product referenced, you will need to include every Klarna BNPL product that you offer.

Klarna's Pay in 3 / Pay in 30 days are unregulated credit agreements. Borrowing more than you can afford or paying late may negatively impact your financial status and ability to obtain credit. 18+, UK residents only. Subject to status. Ts&Cs and late fees apply.

Klarna's Pay in 3 / Pay in 30 days are unregulated credit agreements. Borrowing more than you can afford or paying late may negatively impact your financial status and ability to obtain credit. 18+, UK residents only. Subject to status. Ts&Cs and late fees apply.

Klarna's Pay in 3 / Pay in 30 days are unregulated credit agreements. Borrowing more than you can afford or paying late may negatively impact your financial status and ability to obtain credit. 18+, UK residents only. Subject to status. Ts&Cs and late fees apply.

Klarna's Pay in 3 / Pay in 30 days are unregulated credit agreements. Borrowing more than you can afford or paying late may negatively impact your financial status and ability to obtain credit. 18+, UK residents only. Subject to status. Ts&Cs and late fees apply. klarna.com/uk/terms-and-conditions

Klarna's Pay in 3 / Pay in 30 days are unregulated credit agreements. Borrowing more than you can afford or paying late may negatively impact your financial status and ability to obtain credit. 18+, UK residents only. Subject to status. Ts&Cs and late fees apply.

Please include this disclosure underneath your post:

Klarna's Pay in 3 / Pay in 30 days are unregulated credit agreements. Borrowing more than you can afford or paying late may negatively impact your financial status and ability to obtain credit. 18+, UK residents only. Subject to status. Ts&Cs and late fees apply.

Klarna's [Pay in 3] [Pay in 30] is an unregulated credit agreement. Borrowing more than you can afford or paying late may negatively impact your financial status and ability to obtain credit. 18+, UK residents only. Subject to status. Late fees apply. By continuing I accept the [Pay Later Terms] [Pay in 3 terms].

Limited space disclosure:

18+, T&C apply, Credit subject to status.

If you are not authorised by the FCA, unless you are using Klarna's OSM your asset MUST have Klarna's approval to avoid committing a criminal offence.

Are you advertising Pay in 3 or Pay Later in 30 in the UK? ☑️

Does your ad include an “invitation to credit”? ☑️

If so, you MUST:

  • Use Pre-Approved prompts only
  • Make it clear that Klarna is a form of credit.
  • Be balanced - does not emphasise the benefits without also including the risks of taking out credit
  • Include a disclosure
  • Follow our Prominence Rules
  • Follow our Placement Rules
  • Ensure onsite messaging incl. banners with approved Klarna messaging is updated
  • Ensure the Klarna landing page is up-to-date, visible and easily accessible within the navigation of your website.
  • Ensure FAQs page are up-to-date, visible and easily accessible within the navigation of your website
  • Email/CRM - BNPL Disclosures are included wherever there is an invitation to credit and at the bottom of emails when talking about Klarna’s BNPL products
  • BNPL Disclosures are included for all channels in use (TV, Billboard (Print or Digital), Website, Radio or Podcast & Social Media)
  • Klarna T&Cs are one click away from the point of communication for all channels in use

If yes, SUBMIT YOU ASSET FOR APPROVAL BY KLARNA.
If in doubt, use Klarna On-site messaging.

When referencing Klarna products, you MUST use the appropriate disclosure or your promotion will not be approved by Klarna. Disclosures must follow the Klarna Financial Promotion Rules, including the Prominence Rules and the Placement Rules.

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

No disclosure:

If you use one of the three prompts below, it is not a Financial Promotion and no disclosure is required:

  • “Klarna available”.
  • “Klarna available at checkout”; or
  • [Klarna logo]

Pay in 3 - disclosure required:

Below are some examples of PRE-APPROVED invitations to credit that will trigger the need to add the Pay in 3 BNPL Disclosure.

  • “Pay in 3 with Klarna”
  • “Split your purchases into 3 interest-free payments”

Klarna's Pay in 3 is an unregulated credit agreement. Borrowing more than you can afford or paying late may negatively impact your financial status and ability to obtain credit. 18+, UK residents only. Subject to status. Late fees may apply. Ts&Cs apply.

Pay in 30 - disclosure required:

Below are some examples of PRE-APPROVED invitations to credit that will trigger the need to add the Pay in 30 BNPL Disclosure.

  • “Try before you buy”
  • “Try before you buy. Get 30 days to pay”
  • “Shop now. Pay in 30 days with Klarna”.

Klarna's Pay in 30 is an unregulated credit agreement. Borrowing more than you can afford or paying late may negatively impact your financial status and ability to obtain credit. 18+, UK residents only. Subject to status. Late fees may apply. Ts&Cs apply.

Klarna joint BNPL disclosure required:

Below are some examples of PRE-APPROVED invitations to credit that will trigger the need to add the Joint BNPL Disclosure.

  • “Get more time to pay with Klarna”
  • “Split your purchases into 3 interest-free payments”
  • “Shop now. Pay over time with Klarna”
  • “Shop now. Pay with Klarna.”
  • “Flex your payments.”
  • “Pay Instore with Klarna”.

Klarna's Pay in 3 / Pay in 30 days are unregulated credit agreements. Borrowing more than you can afford or paying late may negatively impact your financial status and ability to obtain credit. 18+, UK residents only. Subject to status. Late fees may apply. Ts&Cs apply.

If you are ever unsure about which disclosures are required, please contact your Klarna contact or Merchant Support before you submit your financial promotion for approval.