What is CCD2 (the second Consumer Credit Directive)?

CCD2 is the EU’s second Consumer Credit Directive, adopted in 2023, which modernises and expands consumer credit regulation across the EU, including bringing more BNPL arrangements into scope.

When does CCD2 start to apply?

Member States must transpose CCD2 into national law by the end of 2025, with full application during 2026, so affected organisations should prepare well in advance.

How can CCD2 affect BNPL and deferred payment in e-commerce?

CCD2 can require BNPL and similar deferred payment flows to meet consumer credit obligations, including creditworthiness assessment and clear pre-contractual information, often using standardised documentation such as SECCI.

CCD2

CCD2, the second Consumer Credit Directive, governs lending to consumers across the EU and introduces far-reaching changes to the credit market.

Explained – what is CCD2?

CCD2 is the second Consumer Credit Directive, adopted by the EU in 2023. It must be transposed by Member States by 2025 with full application in 2026. Compared with the first directive, the second extends consumer credit regulation and now also captures interest-free and fee-free arrangements, including so-called “Buy Now, Pay Later” solutions. This means more providers fall under rules previously applicable to traditional loans. A central feature of CCD2 is the new framework for BNPL services (bnpl), requiring many e-commerce merchants and financial actors to adapt their processes.

CCD2 is rooted in the EU’s objective of a consistent level of consumer protection in the credit market. The rules address areas such as creditworthiness assessment, pre-contractual information, contract terms and consumer rights.

When does the second Consumer Credit Directive become relevant?

The second Consumer Credit Directive is relevant whenever businesses offer consumer credit. This is particularly the case for e-commerce merchants and payment service providers offering deferred payment. For example, a bnpl service that previously was not classified as consumer credit will now be subject to extensive requirements similar to those that already applied to traditional loans. Banks and finance companies that are already subject to supervision must also review their processes to ensure they meet the new requirements.

Illustration of lawyer examining a “Buy now, pay later” online offer with magnifying glass, symbolising legal review of BNPL products, consumer credit compliance and the Second Consumer Credit Directive.

Key considerations under CCD2

Organisations affected by CCD2 should prepare across multiple areas to ensure compliance. The following are central actions to address:

Ensure that the creditworthiness assessment uses reliable information and is properly documented.
Align credit terms so that they are clear, transparent and consistent with national cost and interest-rate caps.
Introduce procedures to provide standardised pre-contractual information, for example using the SECCI form (secci form).
Ensure the right of withdrawal and complaint handling procedures operate in line with the directive’s requirements.
Review existing BNPL set-ups and assess whether changes are needed to meet the new bnpl rules.
Train staff and develop internal processes to meet the obligations on consumer disclosures.

By taking these steps in good time, businesses can mitigate legal risk and establish a solid basis for offering credit under the new consumer credit regulation.

CCD2

Why is the second Consumer Credit Directive important?

The second Consumer Credit Directive is important because it changes the rules of the game for credit across the EU. Consumers gain stronger protection and better opportunities to make informed decisions before entering a credit agreement. For credit providers, it creates duties to enhance transparency and the quality of the creditworthiness assessment.

For companies operating across Europe, the directive requires alignment with EU law and national transposition measures. This affects everything from contract drafting to the technical solutions used for credit checks and information delivery.

In the longer term, the second Consumer Credit Directive will foster greater trust between consumers and lenders. Early adopters can also create competitive advantages by offering robust and legally sound credit solutions, including compliant bnpl services.

The second Consumer Credit Directive brings more credit solutions, including bnpl, into scope with requirements on information, creditworthiness assessment and consumer protection.

The directive must be implemented into national law by the end of 2025, with full application during 2026. Businesses should begin preparations now.

E-commerce merchants must adapt bnpl solutions to meet consumer credit requirements. This may include:

Carrying out a creditworthiness assessment before purchase.
Adjusting fee models to avoid exceeding statutory caps.
Providing clear and standardised information to the consumer (e.g. via a SECCI document).

The aim is to strengthen consumer protection because BNPL is, in practice, a form of credit. Including these services ensures consumers receive similar rights to those applicable to traditional loans.

The responsibility lies with the creditor, which may be a bank, a finance company, a fintech or an e-commerce merchant offering deferred payment. These actors must implement procedures to meet all requirements.

CCD was the first consumer credit directive, laying the foundation for harmonised rules across the EU. CCD2 modernises and broadens the scope, strengthens consumer protection and covers more credit solutions:

CCD focused mainly on traditional loans.
CCD2 also includes interest-free and fee-free credit.
CCD2 imposes stricter requirements on information, the creditworthiness assessment and the right of withdrawal.

BNPL providers and e-commerce merchants should map products and flows against CCD2, remediate gaps in disclosures, contracts and controls, and evidence compliance through governance, training and testing.