Second Consumer Credit Directive applies
Confirmed
Affects you
The second Consumer Credit Directive (CCD2) updates EU rules on consumer loans, including the creditworthiness assessment (the check of whether a borrower can repay) and the information given to borrowers. National rules apply from 20 November 2026.
What it is
The second Consumer Credit Directive (CCD2), Directive (EU) 2023/2225 (external site), sets EU rules for consumer credit: loans to individuals to buy goods and services, such as personal loans, overdrafts and instalment credit. Mortgage-secured credit is outside it.
It aims to make sure that consumers get clear information, borrow only what they can repay and are protected when they fall into difficulty. It replaces the 2008 Consumer Credit Directive from 20 November 2026 (EUR-Lex (external site)).
What changes
The scope widens. Credit of less than EUR 200 and interest-free credit, left out by the 2008 rules, now fall within it, with some exclusions (EUR-Lex (external site)).
The upper limit rises from EUR 75,000 to EUR 100,000. As an example, an unsecured consumer loan of EUR 90,000 was outside the 2008 directive and is covered by the new one (MFSA (external site)).
The creditworthiness assessment, the check of whether a borrower can repay, rests on relevant and accurate information on income, expenses and other financial circumstances. It cannot use special categories of personal data, such as health data (EUR-Lex (external site)).
Where the assessment uses automated processing, the consumer can obtain human intervention and a clear explanation of the assessment. A rejected applicant is told without delay and, where relevant, referred to debt advice services (EUR-Lex (external site)).
Advertising carries a clear and prominent warning that borrowing costs money. Pre-contractual information is given in the Standard European Consumer Credit Information form, with a free copy of the draft agreement on request (EUR-Lex (external site)).
Member States act against excessively high borrowing costs, for example through caps. Creditors exercise reasonable forbearance, where appropriate, before starting enforcement (EUR-Lex (external site)).
Who it affects
The rules apply to creditors and credit intermediaries, including banks and payment institutions that grant consumer credit (EUR-Lex (external site)). The roles most directly concerned:
- Loan Officer (Retail & SME Lending): gives the standard information form and explains rejections under the new rules.
- Credit Risk Analyst: sets which income and expense data feed the creditworthiness assessment.
- Credit Risk Model Developer: documents automated scoring so that its logic can be explained to applicants.
- Collections & Recoveries Specialist: applies forbearance measures before enforcement.
- Conduct Risk Analyst: checks advertising and pre-contractual information against the new duties.
- Compliance Officer: tracks national transposition in each country where consumer credit is offered.
Timeline
The directive was adopted on 18 October 2023 and entered into force on 19 November 2023 (EUR-Lex (external site)). Member States had to transpose it by 20 November 2025, and their national rules apply from 20 November 2026 (EUR-Lex (external site)).
The 2008 directive is repealed on the same date. Existing agreements keep the old rules until they end, although some provisions also reach open-end credit agreements already running on 20 November 2026 (EUR-Lex (external site)).
In its January 2026 infringements package, the Commission opened procedures against 23 Member States for not communicating complete transposition (Commission (external site)). The 20 November 2026 application date is confirmed (Commission (external site)).
Background
The 2008 Consumer Credit Directive, Directive 2008/48/EC, set common EU rules on information to borrowers and on creditworthiness checks. The Commission proposed its revision in 2021 (EUR-Lex (external site)).
The new directive extends those rules to small and interest-free credit, and adds rules on advertising, borrowing costs and forbearance (EUR-Lex (external site)).
Dates
- National CCD2 rules applyConfirmed
Who must comply
Cities where it applies
Processes
Roles affected
30 roles are directly affected: they run one of these processes.
- Agency Operations Analyst
- Collections & Recoveries Specialist
- Company Secretary (Listed Companies)
- Compliance Officer
- Conduct Risk Analyst
- Corporate Banking Analyst
- Corporate Credit Analyst
- Credit Research Analyst
and 22 more
- Credit Risk Analyst
- Credit Risk Model Developer
- Data Scientist (Banking)
- Debt Capital Markets Analyst
- Family Office Analyst
- Leveraged Finance Analyst
- Loan Officer (Retail & SME Lending)
- Loan Operations Analyst
- Merchant Underwriting & Risk Analyst
- Paraplanner / Financial Planning Analyst
- Private Banking Analyst
- Private Credit Analyst
- Project Finance Analyst
- Regulatory Change Analyst
- Reinsurance Analyst
- Relationship Manager (Corporate & Business Banking)
- Restructuring & Turnaround Analyst
- Retail Banking Advisor
- Securitisation Analyst
- Trade Finance Analyst
- Transaction Banking Analyst
- Underwriting Analyst
Also relevant: 13 roles
- Balance Sheet Control Analyst
- Corporate Treasury Analyst
- Equity Capital Markets Analyst
- External Audit (Financial Services)
- Financial Services Consultant
- Markets Sales Analyst
- Private Equity Analyst
- Regulatory Consultant (Banking)
- Regulatory Reporting Analyst
- Structuring Analyst
- Trade Finance Operations Specialist
- Trading Analyst
- Treasury Analyst
What to prepare
- Check the national transposition in each country where consumer credit is offered.
- Review creditworthiness checks and the data sources they use.
- Update pre-contractual information and advertising to the new national rules.
General information, not advice
Source
MFSA circular on Directive (EU) 2023/2225 on credit agreements for consumers (external site)
History
- Status set to in_force: directive in force since 19 November 2023, applies from 20 November 2026. https://eur-lex.europa.eu/eli/dir/2023/2225/oj/eng