CCD2 implementation. What has happened and what it means for lenders.
The EU Consumer Credit Directive, CCD2 (2023/2225), should now be implemented across all EU member states. The official deadline was 20 November 2025, which means every member country should now have transposed the directive into national law.
In Denmark, the Parliament approved the proposal without material changes. The law will take effect on 20 November 2026, which gives lenders a transition period to adjust their processes.
Across the Nordics and Europe, lenders are now focusing on strengthening documentation, improving the reliability of financial data and creating processes that are easy to explain to the respective authorities.
Late November 2025, the Consumer Ombudsman in Denmark published new guidance on creditworthiness assessments. While national details differ, the overall direction across Europe is the same. Authorities expect transparency, thorough documentation and a clear understanding of the applicant’s financial situation.
What we see in the market
Although some legal interpretations are still being refined, several themes appear consistently when speaking with lenders.
• Assessments must be based on reliable and factual data
• Decisions must be consistent and clearly documented
• Supervisors expect creditworthiness assessments that can be explained and justified
• Lenders are focusing on both compliance and lending quality
These trends match what we see every day. Lenders want processes that are clear, consistent and practical for case handlers.
Real account data supports this direction by giving a factual and up to date view of income, expenses and commitments. This helps reduce risk, improve documentation and support the expectations that supervisors are now setting across Europe.
Looking Ahead
With CCD2 formally implemented across Europe, the focus has shifted from preparation to practical execution. National regulators are already refining their interpretations, and lenders are adjusting their processes to match both EU requirements and local supervisory expectations. This makes operational clarity more important than ever, especially when documentation, consistency and portfolio quality are under increased pressure.
To support this, we have developed a whitepaper that provides a clear breakdown of Article 18 and its implications for creditworthiness assessments. It outlines the key requirements, important timelines and practical considerations for aligning lending processes with regulatory expectations.
Insights about the CCD2 Implementation
If you want a structured overview of what CCD2 requires in practice, our whitepaper summarises the essentials in a simple and accessible way. It covers the regulatory foundation, critical deadlines and examples of how lenders can strengthen the quality and documentation of their assessments without adding unnecessary friction. Download the whitepaper to explore the topic further.
