Expanded scope

CCD II now covers a much wider range of credit products, including:

• Credit agreements from below €200 up to €100,000, including microloans, payday loans, and higher-value financing.

• Interest-free and deferred payment products (think BNPL and device financing), even if there’s no interest.

• Leasing agreements with an option to buy (e.g., leasing a device with a purchase option).

• Short-term credits, even those to be repaid within three months if there are fees.

• Bundled and ancillary offers, where credit is part of a package or comes with other services.

If you offer any form of consumer credit, even as a side service, CCD II likely applies to you.

Responsible lending and creditworthiness

No more “rubber-stamping” credit approvals. A creditworthiness assessment is vital to avoid irresponsible lending practices and over-indebtedness of consumers. This means:

• Credit providers must assess each consumer’s financial situation using relevant data (income, expenses, liabilities).

• Checks must be proportionate to the product, no unnecessary data collection.

• No use of sensitive or social media data in assessments.

If automated decision-making is used, consumers have the right to a human review and an explanation if credit is denied.

Enhanced pre-contractual information

Consumers need the facts, upfront and in plain language:

• Credit providers must deliver the Standard European Consumer Credit Information (SECCI) form in a consistent format.

• Essential info goes on the first page for easy comparison, even on mobile.

• Pre-contractual information must be provided well before signing. If it’s less than a day in advance, a reminder about the right to withdraw is required.

• Providers must offer clear explanations to help consumers assess if the product fits their needs.

Ban on tying practices

No more forcing consumers to buy bundled products.

• Credit agreements can’t be tied to other products or services unless strictly necessary (e.g. mandatory insurance).

• If insurance is required, consumers get at least three days to compare offers.

• No pre-ticked boxes, consent must be explicit.

• No unsolicited credit offers or pre-approved cards.

Stronger enforcement and licensing

Only authorised, accountable businesses can offer consumer credit:

• All credit providers and intermediaries must be authorised or registered with national authorities.

• SMEs may be exempt if they only offer ancillary, interest-free credit with minimal late fees, but large enterprises can’t use these exemptions.

Harmonisation with local flexibility

CCD II harmonises the core rules but leaves some flexibility for member states, especially for low-risk or short-duration products. Keep an eye on local developments.