The revised Consumer Credit Directive (CCD2) is one of the most significant regulatory developments affecting lenders, Buy Now Pay Later (BNPL) providers and embedded finance platforms across Europe.
While much of the industry’s attention has focused on PSD2, PSD3 and the upcoming Financial Data Access (FiDA) framework, CCD2 introduces a new set of requirements that could accelerate the adoption of Open Banking solutions.
What is CCD2?
CCD2 modernises the European Consumer Credit Directive and significantly expands its scope. The directive aims to strengthen consumer protection and ensure responsible lending practices across the European Union.
One of the most important changes is that smaller credit products, including many BNPL offerings and micro-credit solutions, now fall within the scope of consumer credit regulation. Organisations offering these products will be required to conduct robust creditworthiness assessments and demonstrate that lending decisions are based on reliable and verified information.
Why does this matter?
Traditionally, affordability checks often relied on customer-declared information, manual document collection or static credit bureau data. CCD2 raises the bar.
Credit providers must increasingly be able to demonstrate that their assessments are based on accurate, current and verifiable financial information.
At the same time, consumers expect fast and seamless digital experiences. This creates a challenge: how can organisations perform robust affordability assessments without introducing friction into the customer journey?
Open Banking as an enabler
Open Banking offers a practical answer. Using Account Information Services (AIS), financial institutions can access customer-permissioned bank account data in real time.
This enables organisations to:
- Verify income streams
- Identify recurring expenses
- Detect existing financial obligations
- Gain a more accurate view of disposable income
- Support faster and more informed lending decisions
Rather than relying on manually submitted documents, organisations can obtain a real-time picture of a consumer’s financial situation through secure API connections.
The importance of data quality and compliance
CCD2 is not only about collecting more data. It is equally about using data responsibly. The directive places strong emphasis on proportionality, transparency and data minimisation. Financial institutions must ensure that only relevant financial information is used in the decision-making process and that customers receive clear explanations of lending decisions.
As a result, organisations need access to data infrastructure that supports both operational efficiency and regulatory compliance.
How IBANXS can help
IBANXS provides access to banking data through a single pan-European Open Banking connection covering more than 2,500 banks.
Our Account Information Services (AIS) capabilities help lenders, fintechs, BNPL providers and embedded finance platforms obtain reliable financial data quickly and securely.
By simplifying access to banking data, IBANXS enables organisations to:
- Streamline affordability assessments
- Improve customer onboarding experiences
- Support CCD2 compliance initiatives
- Scale Open Banking capabilities across multiple European markets
- Reduce integration complexity through a single API connection
Preparing for the future
Although implementation timelines differ across European markets, organisations should already be evaluating the impact of CCD2 on their products, customer journeys and compliance processes.
For many lenders and embedded finance providers, Open Banking will become an increasingly important component of responsible, compliant and customer-friendly credit assessment.
IBANXS is ready to help organisations navigate this transition and unlock the opportunities created by the next generation of consumer credit regulation.