New licensing requirement for consumer credit from July 2025 – what applies to lenders and intermediaries?

On 1 July 2025, the Certain Consumer Credit Operations Act will be repealed. All parties offering consumer credit, including indirectly through intermediation, must then hold authorisation as a bank or credit market institution under the Banking and Financing Business Act (2004:297). This reform marks a fundamental shift in financial regulation in Sweden and will significantly affect several categories of actors that currently conduct consumer credit activities.

For fintech companies that issue or intermediate credit, this entails a material increase in the requirements to continue operating – moving from authorisation as a consumer credit institution under the Certain Consumer Credit Operations Act (2014:275) to needing to become a bank or a credit market institution. In this text we explain what applies, what remains unclear, and how you as a market participant should act.

Transitional rules and timeline

• 1 July 2025 – the new legislation enters into force.
• 31 July 2026 – last day to operate under the transitional rules (if applicable to your business).

During this transitional period, firms that currently hold authorisation under the repealed act may continue to conduct their activities, provided that an application for authorisation under the Banking and Financing Business Act is submitted on time.

What does the licensing requirement as a bank or credit market institution involve?

Obtaining authorisation as a credit market institution or a bank entails significantly stricter requirements than the current framework. Key requirements include:

• Capital adequacy and ownership assessment.
• Governance and control functions (including risk management, compliance and internal audit).
• Management of conflicts of interest.
• Business plan and business model.
• IT and information security.

These requirements apply to both credit providers and credit intermediaries that in practice offer consumer credit, even if they do not themselves issue credit. For credit intermediaries, the requirement to obtain authorisation as a credit market institution or bank is particularly challenging, as many do not conduct deposit-taking and several do not currently issue credit.

Ongoing uncertainty for credit intermediaries

Although the Swedish Parliament has now decided to repeal the previous act, several practical and legal uncertainties remain – particularly regarding the role of credit intermediaries. For example, it is not yet clear how the Swedish Financial Supervisory Authority (FI) will assess business models where the core is not proprietary lending and deposit-taking, nor to what extent such models will need to be adapted to conduct those activities.

Offering consumer credit under the new requirements

If you currently operate in the consumer credit market without authorisation under the Banking and Financing Business Act, it is time to begin analysing how the business should be conducted going forward. This applies to both credit providers and credit intermediaries.

• Conduct a legal review of your business model.
• Establish a plan to obtain new authorisation, including resources, budget and timetable.
• Ensure you meet requirements on governance, controls and capital.

How Morling Consulting can assist

At Morling Consulting, our fintech lawyers have extensive experience of financial regulation, authorisation processes and strategic advice for financially regulated businesses. With us you receive reliable and transparent support throughout the transformative journey that companies engaged in consumer credit activities will need to undertake.