The new Consumer Credit Directive extends well beyond traditional lenders. Here is a clear overview of who needs to act, and why Open Banking is at the centre of the answer.
Consumer Credit Directive 2 (CCD2) is set to reshape the European consumer credit landscape. For the first time, a mandatory, verified affordability assessment is required for every credit decision. Regardless of the size of the transaction or the type of product. That shift affects a far wider group of organisations than many realise.
CCD2 is a European directive, which means each member state has room to shape its own national implementation. At the time of writing, several details — including how individual countries will apply certain provisions — are still being finalised. This article reflects the current state of knowledge and will be updated as national implementations become clearer.
The companies that need to prepare fall into three distinct groups.
Group 1: The directly regulated
Lenders, BNPL providers and consumer credit institutions
These organisations carry the legal responsibility to conduct a full, objective and verified affordability check on every transaction, starting at €0. They operate under direct regulatory supervision from national financial authorities.
✔ BNPL providers such as Klarna, Riverty and in3 face the most significant change. A fast internal risk score no longer suffices. Every e-commerce transaction now requires a compliant creditworthiness assessment.
✔ Traditional consumer credit providers. Banks and finance companies offering personal loans or revolving credit, already conduct affordability checks, but must now meet stricter CCD2 standards on data minimisation and explainability. Consumers have the right to human intervention when declined.
✔ Auto financiers and private lease providers must make their acceptance processes more structured and fully auditable.
✔ Micro-lenders offering short-term, small-value loans face a particularly acute challenge: the combination of mandatory checks and interest rate caps makes the current business model unworkable without deep automation.
Group 2: The indirectly affected
Merchants, service providers and adjacent industries
These organisations are not credit providers by nature, but their operational processes or revenue streams are directly tied to deferred payment and credit arrangements.
✔ E-commerce and retail: webshops offering pay-later at checkout will experience increased friction at the point of purchase. As consumers are required to complete an Open Banking verification before a BNPL transaction is approved, conversion rates come under pressure. Rethinking the checkout experience becomes a business priority.
✔ Debt collection agencies and bailiffs: under CCD2, a payment arrangement that includes interest or administrative fees is classified as a new credit agreement, triggering licensing and assessment obligations. The practical outcome: free, interest-free payment plans become the default across the sector.
✔ Energy companies: deferred payment for billing arrears falls outside the scope of CCD2 as long as it is offered free of charge within a limited timeframe. The moment costs are attached or invoicing is transferred to an external factoring party, consumer credit law applies.
✔ Insurers: CCD2 prohibits the bundling of credit products with payment protection insurance (tying arrangements) and bans pre-ticked boxes in digital customer environments.
✔ Telecoms providers: companies selling devices on instalment or lease arrangements face growing administrative pressure to demonstrate affordability, including on lower-value handsets.
Group 3: The enablers
Open Banking infrastructure and data providers
For this group, CCD2 represents commercial opportunity rather than compliance burden. Real-time, bank-verified financial data becomes mandatory infrastructure for every credit decision.
✔ Open Banking gateways (AIS providers) become essential: the API connectivity to retrieve verified transaction data in real time, directly at the point of application, is the technical foundation that all compliant credit decisions now require.
✔ Data enrichment and credit scoring fintechs that specialise in categorising raw bank transaction data, translating it into clear metrics such as stable income and fixed expenses, provide the analytical layer needed to make a compliant decision within seconds.
✔ Traditional credit registers such as BKR will see a significant rise in query volumes as BNPL transactions that were previously unchecked now require mandatory bureau lookups.
What a compliant CCD2 affordability check requires
A compliant CCD2 affordability check requires:
✔ Current account data, verified at the moment of application
✔ Income and expenditure categorised into clear, explainable metrics
✔ Delivered within the timeframe of a checkout or loan application
That is precisely what Account Information Services (AIS), the Open Banking layer, are built to provide.
How IBANXS can help
At IBANXS, we provide direct API connectivity to more than 2,500 banks across Europe through a single integration. Lenders, BNPL providers, fintechs and their technology partners use our Account Information Services to retrieve the real-time, verified bank data needed to power fast, accurate and fully compliant affordability decisions.
CCD2 compliance starts with the right data infrastructure.
Want to know how IBANXS fits into your CCD2 compliance journey? Get in touch.