CCD2 for lenders: what changes from November 2026 and how to prepare

What is CCD2 and when does it apply?

CCD2 is the new EU directive on credit agreements for consumers. It replaces the 2008 Consumer Credit Directive, which was written before smartphones, instant online loans and buy now, pay later became mainstream.

Member states had to transpose CCD2 into national law by 20 November 2025, and the new rules apply from 20 November 2026. Because it is a directive, the exact wording, some thresholds and optional exemptions depend on each country's implementing law – always check the national version in every market you serve.

Which products are now in scope?

The biggest practical change is scope. Many products that used to sit outside consumer credit rules are now covered.

• Loans up to €100,000 (the old ceiling was €75,000).
• Small loans below €200, which were previously excluded.
• Many interest-free and buy now, pay later arrangements, especially where a third-party lender is involved, subject to limited exemptions.
• Overdrafts and some short-term credit that were previously exempt or lightly regulated.

Stricter creditworthiness assessment

CCD2 requires a thorough assessment of whether the consumer is likely to meet their obligations, based on relevant and accurate information on income and expenses and other financial and economic circumstances.

It also restricts the data that may be used: special categories of personal data, such as health data, cannot be used, and personal data from social networks should not be used for this purpose. Where the assessment involves automated processing, the consumer has the right to request human intervention, an explanation and to contest the decision.

For lenders this means every decision must be documented: which data was used, which rules applied and why the outcome was approve, decline or refer.

Disclosures, advertising and selling practices

Pre-contractual information must be clear and timely, with key information presented in an overview at the top of the standard form. Advertising must include standard information and a clear warning that borrowing money costs money.

The directive also limits practices that can harm consumers: unsolicited credit is prohibited, tying practices are restricted, and member states must take measures against excessively high interest rates or total costs, for example through caps.

• Review advertising templates, landing pages and calculators.
• Check that the standard information form and the APR calculation are generated from the same data as the contract.
• Make sure consents for any optional products are separate and recorded.

Forbearance and arrears handling

Before starting enforcement, lenders must have adequate policies to show reasonable forbearance to consumers in difficulty. This can include refinancing, changing the term, the type of agreement or deferring payments.

Collection strategies should therefore include documented forbearance options, contact rules and the ability to restructure loans without manual spreadsheet work.

A practical CCD2 readiness checklist

Most lenders do not need a new business model, but they do need proof. A good starting point is to compare each product with the national law and check whether your systems can produce the evidence a supervisor would ask for.

• Map every product against the new scope, including BNPL and small loans.
• Update creditworthiness rules and record inputs, rules and reasons for every decision.
• Offer human review of automated decisions and log the outcome.
• Refresh pre-contractual documents, APR calculation and advertising templates.
• Add forbearance options to servicing and collection workflows.
• Train staff and keep training records.

Frequently asked questions