CCD2: The directive that is changing credit rules in Europe

Starting from November 20, 2026, all consumer credit players in Europe will have to apply the CCD2 directive (Consumer Credit Directive 2).

This regulation puts an end to two practices that have hitherto been common:

- The declarative : “I earn €3,000 per month” → now, I'll have to prove it

- The Opaque scoring : “You were refused” → from now on, we will have to explain why

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In plain language: CCD2 imposes a systematic solvency check based on real and verified financial data, with a total transparency on decisions.

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Important: CCD2 only applies to loans to individuals (B2C).

Business loans (B2B) are not affected by this directive.

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The calendar to remember

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• October 18, 2023: Publication of the European CCD2 directive

• November 19, 2023: Entry into force at European level

• September 3, 2025: Transposition in France (ordinance No. 2025-880)

• November 20, 2025: Deadline for transposition in all Member States

• November 20, 2026: MANDATORY AND SANCTIONABLE APPLICATION everywhere in Europe

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You have until November 2026 to comply.

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1. What does CCD2 change in concrete terms?

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Expanding the perimeter

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The CCD2 directive considerably broadens the scope of application of consumer credit:

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Concretely:

• A 3× purchase at no cost of €50 → Considered as a credit

• A bank overdraft for an individual → Mandatory solvency assessment

• A car LOA for an individual → Reinforced checks (if fixed term + purchase option)

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2. The 3 pillars of CCD2

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Why this change? The multiplication of BNPLs and micro-loans has created a risk of over-indebtedness for consumers. CCD2 aims to protect individuals by requiring a systematic assessment of their ability to repay.

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1 - Systematic solvency assessment

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Before: Low amount = no verification

After: Mandatory verification for all credits (even €50) via Open Banking

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Example: A customer buys sneakers at €120 in 4×
→ Open Banking Connection → Instant Analysis → Decision in 2 seconds

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2 - Real and verified data

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Before: “I earn €2,500/month” → Declarative without proof

After: Revenues, expenses and debts verified by reliable sources

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✓ Allowed

• Bank statements (Open Banking)
• Pay slips
• Credit Bureaus (FICP)

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✗ Forbidden

• Health data
• Social networks
• Behavioral data

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3 - Explainable AI and transparency

Before: “Credit declined” → No explanation

After: The customer has the right to know why he is being refused

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Link to the AI Act: Credit scoring is ranked “high risk use” by the European AI Regulation (June 2024).

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This imposes three strict obligations:

• Traceability: Each credit decision must be able to be audited and justified a posteriori

• Explainability: The refusal criteria must be clear and understandable for the customer.

• Non-discrimination: AI models should not create any bias (age, gender, origin, etc.)

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In plain language: No more “black box scoring”. Each refusal must be justified with factual and traceable criteria.

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Explanation example:
“Credit refused: insufficient rest to live (€1,200 for €5,000 requested), 3 payment incidents detected, debt ratio 42% (max threshold: 35%)”

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3. Impact by sector

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BNPL & E-commerce

Check creditworthiness in < 2 seconds at the time of payment, without breaking the conversion. Automating compliance through Open Banking can improve conversion rather than degrade it.

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Banks & Credit

Bank overdrafts for individuals become a credit like any other, with the obligation to reassess solvency. For banks that adapt: reduction in unpaid bills. For those who wait: increased risk of extending credit to financially fragile profiles.

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Automotive & Leasing

Individual loa/leasing (fixed term + purchase option) included. The institution must prove that it has assessed repayment capacity on all planned monthly payments (e.g. 48 months), not only when the contract is signed.

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Fintechs & Microcredit

Same approvals as banks. Strict documentation of all decisions is mandatory.

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4. How to prepare?

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Before November 2026, you must:

✓ Integrate Open Banking into your customer journey

✓ Automate solvency scoring (< 2 seconds)

✓ Make your AI explainable (clear refusal criteria)

✓ Documenting all your decisions

✓ Train your teams in regulations

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In conclusion

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CCD2 is not a constraint, it is a opportunity for differentiation.

It will also accelerate the adoption of Open Banking as a European standard for assessing solvency, positioning the players who are preparing for it in advance of the phase.

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For actors who adapt: Compliance + seamless customer experience + reduction in unpaid bills = triple competitive advantage

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For those who are waiting: Risk of sanctions + technological delay + increased exposure to financially fragile profiles

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The countdown has begun: November 2026 is 10 months away.