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The landscape of consumer credit regulation is undergoing a significant transformation before 2025 ends. With the enactment of the European Union’s new Consumer Credit Directive 2023/2225 (CCD2), countries across Europe are racing to transpose these rules into national law by November 2025.

What is CCD2?

The Consumer Credit Directive 2023/2225 (CCD2) is an EU legislative framework designed to harmonize and strengthen consumer credit protections across all EU member states. Adopted in October 2023, CCD2 replaces the earlier 2008 directive, reflecting significant changes in the market driven by digitalization and new credit products.

All EU member states are required to transpose CCD2 into their national laws by November 20, 2025, with the directive becoming fully applicable from November 20, 2026. This directive represents a full harmonization effort, limiting divergent national rules and creating a consistent consumer credit market across Europe.

Status of Transposition in Key European Markets

Here is the current status of CCD2 transposition in important EU markets, accurate as of October 2025:

  • Spain: Legislative progress is ongoing, with final stages of parliamentary review expected to meet the November 2025 deadline. Spain is focusing on regulating fintech consumer credit providers under supervision.
  • Portugal: The Ministry of Finance has launched consultations. A draft bill is expected for parliamentary consideration before the end of 2025.
  • France: Early legislative reviews are in progress, with parliamentary debate scheduled for late 2025.
  • Italy: Government guidelines are published, with active finalization of legal texts aiming for compliance by November 2025.
  • Sweden: The Financial Supervisory Authority is aligning national law with CCD2, expecting full transposition by November 2025.
  • The Netherlands: Legislation is in the final drafting and public consultation phase, on track for timely transposition.
  • Germany: Draft legislation is under parliamentary review, targeting full compliance by November 2026.

Key Changes Coming with CCD2

  • Broader Scope: Regulation now covers small loans (under €200), overdrafts, free loans, and “Buy Now Pay Later” (BNPL) agreements. This is a massive change for all BNPL providers as small loans will now be captured by CCD2 and no longer exempted.
  • Stronger Consumer Protections: Stricter advertising restrictions, clearer and standardized pre-contractual information for consumers, and improved creditworthiness assessments.
  • Digital Disclosures: Electronic communication and contract conclusions are explicitly permitted and encouraged.
  • Interest Rate and Cost Caps: Measures to prevent excessive fees and protect consumers from over-indebtedness.
  • Supervision of BNPL Providers: Third-party BNPL schemes must be authorized and supervised starting from 2026.
  • Transparency and Data Sharing: Enhanced requirements to support responsible lending and detect consumer risk.

Conclusion

2025 is a critical year for consumer credit regulation across Europe as EU member states work to transpose and apply the new Consumer Credit Directive fully.

Organizations involved in consumer credit should prepare for significant compliance actions to align with broader protections, digital practices, and expanded regulation of innovative credit products. Early adaptation will ensure smoother transitions, stronger consumer trust, and avoidance of regulatory penalties.

Sources

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