Danish Creditworthiness Guidelines: What’s Changing Ahead of CCD2

Across the banking and lending industry, creditworthiness rules are back in the spotlight. With the European Consumer Credit Directive’s (CCD2) deadline for national implementation approaching in November 2025, attention is also turning to Denmark’s updated guidelines on creditworthiness assessment.

While we await the CCD2 implementations in Denmark, the Danish authorities have recently published a hearing draft of new guidelines relating to the existing CCD1 implementation. In this first article of our series, we explore how the draft guidelines differ from the current ones, why they have been issued now, and what they mean in practice.

‍The text contains our translated extracts of the Danish draft for the updated guidelines. For the original wording, we refer to the original draft in Danish: Høringsudkast til Vejledning om Kreditværdighedsvurdering, which was published end of June 2025 by the Danish Finanstilsynet (Financial Supervisory Authority/FSA) and Forbrugerombudsmanden (The Consumer Ombudsman).

From Specific to Generic — A Shift in Approach

While the currently effective guidelines consist of a relatively precise overview of what lenders and credit providers should and/or ought to do to perform a credit assessment, the wording in new guidelines is of a more generic nature. This is also indicated by the way it is presented: “the Danish FSA and the Consumer Ombudsman set out a number of general principles for the assessment of creditworthiness”.

The new guidelines will formally repeal the current, effective guidelines. However, the authorities also state that “the method for creditworthiness assessment described in the previously issued guidelines remains in accordance with section 7c of the Credit Agreements Act. Creditors whose creditworthiness assessment process reflects the method described in the previously issued guidelines may therefore continue to use it’.

Why Issue New Guidelines Now?

Why move from highly specific guidelines to more generic ones — and so close to the introduction of CCD2 — if much remains unchanged in practice?

One explanation lies in a Danish court ruling in a case raised by the Danish branch of the lending company Resurs Bank: The ruling states, among other things, that the authorities may not “deprive the credit provider of the discretion provided for in the legislation as to when sufficient information is available”.

What the New Guidelines Clarify

Based on the court ruling, the new guidelines make it clear that the creditor is left with some discretion to make decisions with regards to the sufficiency of data. The text also provides instructions on how such discretion may be exercised.

For example, with regard to the use of (statistically based) estimates rather than actual documented figures, it is specifically stated that “the creditor's eligibility in making use of estimates is limited both in terms of the extent to which estimates may be used and in terms of the types of estimates that may be used”, and these limitations are explained in more detail.

The guidelines also maintain that “simple unsubstantiated statements made by the consumer cannot in themselves qualify as adequate information if they are not accompanied by documentation” and that “the creditworthiness assessment must be based on the specific consumer's personal financial situation”.
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Industry Perspectives

Co-founder at Monthio, Rune Heinrichson, says:

“From the beginning, Monthio has been very familiar with the requirements stemming from the European Consumer Credit Directive (CCD1), which were interpreted into the EU member countries’ local legislation. In fact, the wording of the current Danish guidelines worked as the recipe for developing our solution.”

He adds that ensuring assessments are based on applicants’ real data, rather than mere statistical averages, has since evolved into delivering cross-validated financial information — giving advisors and risk managers a comprehensive financial overview of each applicant.

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‍Steen Van Hauen, who has worked with large financial institutions across the Nordics and recently joined Monthio as VP of Sales, Head of Banking, concludes: “Bottom line is that transaction-based solutions help banks and lenders deliver on the requirements set out in the consumer credit directive.”

He notes that streamlined documentation processes have made regulatory audits far less burdensome for some banks. In his experience, lenders with robust, data-driven creditworthiness assessments are better positioned to demonstrate compliance without excessive manual preparation.

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Looking Ahead

With only months to go before CCD2 becomes law in member states, national regulators are already fine-tuning their own guidelines. For lenders, this means that operational readiness is no longer just about aligning with EU rules — it’s about adapting to local interpretations and enforcement practices.

In our next articles, we’ll look at how Sweden and Finland are approaching the transition, and what this could mean for cross-border operations. Subscribe to stay informed as the regulative situation develops.

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Insights about the CCD2 implementation

Keeping track of the different implications of the CCD2 and how and when it must be compiled to by lenders and financial institutions operating in the European Union is made easy and accessible in this whitepaper "New CCD2 guidelines for creditworthiness assessment - Navigating the article 18 of CCD2." Download  the whitepaper to explore the topic further.