The Government has now presented a bill for a new Consumer Credit Act, Government Bill 2025/26:223, which is proposed to replace the current legislation. For creditors, credit intermediaries and other businesses that offer or participate in consumer credit, the proposal signals a clear shift: the area will become more regulated, more process-driven and subject to more intensive supervision. Businesses affected by the proposal should therefore already be analysing how the framework may affect their business model, routines and internal governance, preferably together with our lawyers working with consumer credit matters.

At the same time, this remains a legislative proposal. Assessments and preparations should therefore be made on the basis that the rules may still be adjusted during the continued legislative process.

A broader scope that may affect more firms than before

A significant change in the bill is that the new Act is proposed to have a broader scope. This means that more types of credit will be covered and that more traders than before will need to comply with the consumer credit framework.

This is particularly important for businesses that do not primarily view themselves as financial actors, but which sell goods or services on credit. For such businesses, the new Consumer Credit Act may mean that information requirements, creditworthiness assessments, documentation and supervision suddenly become central parts of the ongoing compliance function.

Stricter pre-contract information requirements increase demands on process and documentation

The proposal introduces more extensive requirements for information before a credit agreement is entered into. The aim is to ensure that consumers are better able to understand credit terms, costs and risks before making a decision.

For businesses, this is not only a matter of updating contractual terms. In practice, it often requires a review of the entire customer journey: what information is provided, when it is provided, in what format, and how the business ensures that the information is actually clear and comprehensible.

Formal compliance on paper is not enough. The information requirements must be capable of being translated into workable routines in digital flows, sales processes, telephone sales and other distribution channels.

Marketing of credit is proposed to become more clearly regulated

The bill also contains stricter rules on marketing. In particular, it highlights messages that trivialise payment problems or create the impression that credit improves the consumer’s financial position or standard of living.

For affected businesses, this means that marketing, campaign messages and sales support may need to be reviewed more carefully than before. The risks are not limited to traditional advertising, but may also arise in, for example:

• website copy and landing pages,

• social media advertisements,

• sales scripts and customer communication,

• partner and affiliate arrangements.

From a compliance perspective, there needs to be clear internal control over how credit is presented to the market, particularly where messages are developed close to the sales function.

Creditworthiness assessments become an even more important regulatory core issue

Another central part of the proposal is that the rules on creditworthiness assessments are tightened. According to the bill, the creditworthiness assessment must be more thorough and carried out in the consumer’s interest.

This may have practical consequences. For many actors, creditworthiness assessment is already a key issue today, but the proposed framework points towards higher requirements for quality, transparency and reasoning in the assessments. This may in turn affect data collection, decision models and internal follow-up.

For businesses working with automated or partly automated processes, this may raise several issues at the same time, including:

• which data is used in the assessment,

• how proportionality and quality are ensured,

• how decisions are documented,

• how the consumer’s interest is taken into account in practice.

There is a clear link here between credit law, internal control and operational risk management.

More regulation during the term of the agreement increases demands on ongoing administration

The proposal does not only concern the period before the agreement is entered into. During the term of the agreement, more detailed rules are also proposed regarding, among other things, documentation, notifications, changes to credit terms and information to the consumer.

This means that businesses need to review how ongoing administration works after the credit has been granted. In many organisations, responsibility in this area is spread across business operations, customer service, debt collection, legal and compliance. As the regulation becomes more detailed, the risk of deficiencies in handovers, system support and allocation of responsibilities increases.

Late payers and financial difficulties receive greater focus

The bill also points towards greater focus on consumers with payment difficulties. Creditors are proposed to be required to have routines to detect financial problems at an early stage and, in certain situations, consider alternatives to enforcement measures.

This is an area where law and operational activity meet very clearly. It is not only about individual measures against late payments, but about how the business identifies risk, documents assessments and acts in a way that is consistent with the regulatory framework.

Affected businesses should therefore analyse whether existing processes for reminders, debt collection and further measures are adapted to a more far-reaching consumer protection framework.

Authorisation requirements and supervision may become relevant for more actors

A particularly far-reaching change is that more traders are proposed to become subject to authorisation requirements and supervision. This may also affect businesses outside the traditional financial sector, for example businesses that offer or intermediate credit in connection with the sale of goods or services.

For these actors, the issue may be more intrusive than an ordinary legislative change. An authorisation requirement may affect the entire structure of the business, from management and governance documents to control functions, reporting and the relationship with supervisory authorities.

It is therefore a highly important assessment whether the business model may fall within the new requirements. That analysis should be carried out early, particularly in businesses where the credit element has so far been regarded as an ancillary part of the offering.

What businesses should do already now

Although the bill concerns proposed rules and not final applicable law, there are good reasons to begin preparations now. For many businesses, adaptation will require both legal analysis and practical change work.

• Map which products, flows and customer journeys may be covered by the new Consumer Credit Act.

• Review marketing and sales communication with a focus on prohibited or high-risk messages.

• Review routines for creditworthiness assessments, documentation and decision support.

• Analyse processes for changes during the term of the agreement, customer information and notifications.

• Review the handling of late payments and consumers with financial difficulties.

• Assess whether the business may be subject to authorisation requirements or expanded supervision.

For many businesses, this is ultimately a governance issue. The new Consumer Credit Act points towards higher requirements for governance, control and documented compliance, not only legal theory.

At morlings.se, you can find more information about how we work with financial regulation. At Morling Consulting, our lawyers help businesses analyse new regulatory frameworks, adapt internal processes and manage regulatory risks before they become supervisory issues or business obstacles.