CCD2 compliance
Compliance with the EU Consumer Credit Directive 2 (Directive 2023/2225), which replaces the 2008 directive and applies from November 2026. It expands scope, tightens creditworthiness assessment rules, and mandates the use of relevant and accurate data.
CCD2 broadens consumer credit rules to cover small loans, BNPL, and digital channels previously outside scope. Core requirements include rigorous, evidence-based creditworthiness assessments (not just bureau lookups) clearer pre-contractual information, stricter advertising rules, and explicit rules around the use of automated decisioning and personal data. For lenders, the practical impact is invested in better data inputs (income verification, cash-flow analysis) and in explainable decisioning.
The new Directive will be enforced by November 2026. Member states must transpose by November 2025; lenders need to apply the rules from November 2026.