behavioural research
Behavioural Research for European BNPL Providers
Remote behavioural testing for BNPL checkouts, instalment plan selection, and post-purchase repayment flows. We run neurodivergent participants through your real journey, capture voice, interaction, and facial expression in parallel, and return human-confirmed reports your product team can act on before the next CCD deadline.
BNPL is moving inside the perimeter of EU consumer credit law
The recast EU Consumer Credit Directive (2023/2225) brings most BNPL agreements inside the consumer credit framework that previously excluded them. National transposition is underway across Member States, with finance ministries and conduct regulators preparing rules on pre-contractual information, creditworthiness assessment, and the wider Unfair Commercial Practices Directive baseline that already governs how BNPL options are presented at checkout.
For European BNPL providers, the practical pressure points are the merchant checkout widget, the plan selector (pay in 3, pay in 30, longer instalments), the affordability and KYC screens, and the in-app repayment and arrears journey. Each of these has to communicate cost, obligation, and consequences clearly enough that a distracted shopper, not just a lawyer, actually understands what they are agreeing to.
Legal review can tell you the disclosures are present. It cannot tell you whether a shopper with ADHD reads them, whether a dyslexic user can parse the instalment schedule, or whether the late fee warning registers before the confirm button is tapped. That is a behavioural question, and it needs behavioural evidence.
The recast Consumer Credit Directive extends scope to small-amount and short-term credit, including most BNPL agreements, and requires creditworthiness assessments and pre-contractual information; Member States must apply the new rules by 20 November 2026
For European BNPL providers, the recast Consumer Credit Directive is the single regulatory event that reshapes the product. Pay-in-3 and pay-in-30 agreements that previously sat outside consumer credit scope will fall inside it across Member States by the 20 November 2026 application date, which means creditworthiness assessment screens, pre-contractual information disclosure, and the cost and obligation language in the checkout widget all become regulated surfaces rather than marketing surfaces. Legal teams can confirm the required disclosures are present. Only behavioural evidence can confirm a distracted shopper actually reads and understands them before tapping confirm, which is exactly the gap a neurodivergent behavioural research panel is designed to close ahead of national transposition.
Our approach
Test the checkout widget on real merchant pages
We run sessions against your live or staged widget embedded in a representative merchant flow, not a stripped-down prototype. Plan selection, the pre-contractual information screen, and the confirm step are observed in the order a shopper actually meets them.
Three behavioural streams, correlated
Voice (think-aloud), interaction signals including rage clicks and hesitation on the plan selector, and facial expression processed on-device. The AI pipeline correlates the three so you can see where a participant says they understood the schedule but their behaviour says otherwise.
Neurodivergent panel as a higher-signal usability sample
Participants with ADHD, autism, dyslexia, and low vision surface comprehension and attention failures in instalment disclosures that neurotypical testers routinely miss. Useful for CCD readiness work and useful for conversion.
What you receive
- Session recordings of the full BNPL journey from plan selector through pre-contractual information to confirmation, with synchronised voice, interaction, and expression tracks
- Issue log mapped to specific journey steps: widget entry, plan selection, affordability questions, disclosure screen, confirm, and first repayment reminder
- Comprehension findings on cost, APR presentation, late fee warnings, and the instalment schedule, with verbatim participant quotes
- Prioritised recommendations separated into checkout conversion impact and CCD-readiness impact, so product and compliance can plan independently
- Human-confirmed written report plus a working session with your product, design, and compliance leads
Frequently asked
- Does the recast Consumer Credit Directive actually apply to our BNPL product?
- In most cases yes. The 2023 recast extends scope to small-amount and short-term credit including most BNPL agreements, with Member State application by 20 November 2026. Edge cases (zero-cost, very short duration, merchant-of-record structures) need legal review in the relevant Member State. Our reports are usability evidence, not legal opinion.
- How does this relate to UK BNPL, which is not yet under full FCA regulation?
- HM Treasury has confirmed BNPL will be brought into FCA regulation, and FCA-authorised lenders already inside scope are subject to Consumer Duty (PS22/9). For UK-facing BNPL we frame findings around Consumer Duty consumer understanding and consumer support outcomes for firms in scope, and around best practice ahead of the wider regime for firms not yet in scope.
- Can you test our merchant-side checkout widget as well as our own app?
- Yes. Most behavioural failures we see in BNPL sit at the widget on the merchant site, where a shopper first meets the plan options. We test the widget in a realistic merchant context and follow the same participant through the app for KYC, affordability, and the first repayment screen.
- How are you different from Hotjar, Maze, or UserTesting for BNPL research?
- Those tools are good and we complement them. The differences are the neurodivergent panel, the three correlated behavioural streams including on-device facial expression, and human-confirmed reports rather than raw session libraries. We are behavioural user research first, accessibility methodology second.
- How is participant facial expression data handled?
- Facial expression is processed locally on the participant's device using on-device computer vision. We do not ship raw video of faces to our servers. This matters for GDPR review and for participant consent, both of which we document in the engagement pack.
Keep reading
Research hub
Use case
Talk to a behavioural researcher
Tell us about the vertical, the journey, and the evidence you need. We will scope a pilot in days, not weeks.