Dear ESMA,

Trust you are doing fine.

My team and I have been wondering which ESMA template would be needed for B2B BNPL assets. Most essentially, B2B BNPL (“Buy Now, Pay Later”) refers to invoice payments in B2B online shops, i.e. for online business activities between (small- and medium sized) companies. The payment window varies between 14 and 60 days. Upon consultation with European Data Warehouse, we have been told that the B2B BNPL assets would most likely fall under SME or Esoteric, and hence the Corporate/Esoteric Template be needed. Could you please confirm whether this is in line with your judgement?

Thank you very much in advance.

Kind regards,
Noemi Jaekel

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