CCD2 (Consumer Credit Directive)
CCD2 (Consumer Credit Directive): advisory that takes you all the way
CCD2, the updated Consumer Credit Directive, frames how deferred payment and consumer credit may be offered across the EU. In Sweden, implementation is underway with planned application on 20 November 2026, and we operate in and serve clients across Europe. Many businesses therefore need to determine how the changes affect their operations. The question is particularly relevant for e-commerce, marketplaces, payment and BNPL providers, banks and credit intermediaries targeting consumers. Retail and telecoms are also impacted as invoice, instalments and other credit-like offers will be captured. In short, anyone offering or brokering consumer credit needs a clear plan.
The regulation introduces requirements for product design, credit assessment, customer information, marketing and the customer journey before, during and after purchase. Agreements with third-party suppliers and platforms should be reviewed, for example to ensure appropriate allocation of responsibilities and reporting. Data, IT and customer service are affected as identification, KYC flows and documentation must work seamlessly. Good preparation reduces regulatory risk and protects conversion and brand equity. For a practical overview of how invoice, “pay later” and instalments are affected in e-commerce, see our post Invoice, “pay later” and instalments — how e-commerce is affected by the Consumer Credit Directive.
Our advisory helps companies move from regulatory overview to concrete actions. We map what the Consumer Credit Directive means for your business, prioritise gaps and translate them into actions across product, legal, compliance and technology. This includes guidelines, decision materials, updated customer flows, partner appendices and governance documents. We also provide ongoing knowledge transfer and can deliver training so the change is sustained over time. The result is an implementation that is proportionate, traceable and commercially sound.
Consumer Credit Directive: impact on lenders, credit intermediaries and third-party providers
The Consumer Credit Directive broadens when deferred payment falls within the scope of the Consumer Credit Act. In practice, requirements move into product, sales and third-party oversight, and more firms will need authorisation as an intermediary or a lender. For in-scope businesses, this means decisions on responsibility, processes and technology that hold up in production.
- Lender: the party that offers credit in its own name, for example through instalments, invoices with extended payment terms, payment deferral or leasing with a purchase option.
- Credit intermediary: the party that presents credit from a lender and assists a consumer before a credit agreement is concluded.
- Third-party provider: the party that provides a deferred payment solution (for example a BNPL provider) to a merchant.
Assessing roles correctly is critical to applying the Consumer Credit Directive’s requirements proportionately and precisely. Misclassification between lender, credit intermediary and third-party provider risks the wrong allocation of responsibilities, deficient information and inadequate compliance with requirements, for example credit assessment. Clear role-mapping ensures the right CCD2 requirements are implemented with appropriate contracts, processes and controls for each party. In practice, the consumer credit directive 2 will often require that responsibilities and controls are evidenced by logs and audit trails.
Consumer credit
Consumer Credit Directive requirements in the Consumer Credit Act and the law on residential credit activities
The Consumer Credit Directive, often referred to as CCD2, is implemented in Swedish law primarily through the Consumer Credit Act and the updated law governing activities relating to residential credit and certain other consumer credit. The purpose is to provide a uniform standard for how credit is offered, marketed and followed up. Implementation expands both requirements before and during the credit term, and which operators must apply them. As more operators are captured, more firms than before will need authorisation from the Swedish Financial Supervisory Authority (FI) and will need to apply the Anti-Money Laundering Act.
In the Consumer Credit Act, requirements are clarified for lending and deferred payment to consumers, whether offered online or in a physical environment. The regulation covers pre-contractual information, credit assessment, interest and fees, and how terms and risks must be presented transparently. It also captures shorter deferrals and instalments, meaning some merchants’ in-house invoicing will be in scope. These requirements must also be applied in accordance with good credit practice, so that credit is granted only after the lender has considered the customer’s interests.
As CCD2 broadens which arrangements count as consumer credit, more business models — and therefore more actors — are subject to the requirements for issuing and brokering credit to consumers. Payment deferrals, invoices with extended terms, instalments and certain leasing models are captured, requiring action by e-commerce, marketplaces and telecoms with bundled hardware. When an external BNPL or invoice solution is embedded in checkout, the merchant may become a credit intermediary while the solution provider is the lender. The consequence is that more companies must comply with requirements for pre-contractual information via the SEKKI form, creditworthiness assessment, documentation and follow-up for consumer credit. The effect is not only legal but also operational and commercial, as requirements must be embedded in product, sales, customer service and partner governance to work in live flows. Put simply, the consumer credit directive 2 raises the bar for evidence and control, and the consumer credit directive requires that firms demonstrate compliance in practice.
The updated law on residential credit activities will govern authorisations, fit-and-proper assessments of owners and management, and requirements for governance, risk management and reporting. The law also addresses outsourcing, third-party providers and how credit intermediation should be conducted in a controlled manner. For actors integrating external solutions for invoices, instalments or so-called “Buy Now, Pay Later” (BNPL), this means clearer allocation of responsibilities. For a deeper overview for e-commerce, see our post New rules for BNPL — how CCD2 (the Consumer Credit Directive) affects e-commerce.
To meet the requirements in practice, businesses need to map which offerings and customer flows are captured by the new rules, define role allocation between lender, credit intermediary and third-party provider, and review contracts and processes. Documentation, logging and training must support credit assessment, customer information and complaints handling. A proportionate application reduces regulatory risk and enables a customer journey that complies with the law while preserving conversion.
We deliver tangible outcomes in your CCD2 alignment
Morling Consulting translates the Consumer Credit Directive requirements into working solutions in your business across Europe. The goal is alignment that reduces regulatory risk while protecting revenue and customer experience. We work from an “in-house perspective” to ensure the advice delivers real value in operations, shortening lead times and costs for CCD2 alignment. The delivery is measurable, traceable and maintainable even after our engagement ends.
- Preparing the authorisation application to the Swedish Financial Supervisory Authority (FI) with all appendices
- Gap analysis per product and customer flow
- Allocation of responsibilities between lender, credit intermediary and third-party provider
- Policy and guidelines for credit assessment and documentation requirements
- Preparation of pre-contractual information and general terms
- Review of copy and UX content for checkout and the customer journey before, during and after contract
- Logging requirements to evidence compliance
- Incident and complaints handling with roles, processes and reporting lines
- Training packages for sales, support and product teams
Morling Consulting adds practical capacity where it delivers most value in aligning with the Consumer Credit Directive (ccd2). We interpret and concretise the requirements, design processes and specify system needs. Our lawyers have operational experience leading licensed consumer credit operations and combine this with deep understanding of the incoming requirements and how to progress matters efficiently with the Swedish Financial Supervisory Authority (FI) and the Swedish Consumer Agency. The result is proportionate, measurable and maintainable solutions that reduce risk, secure compliance and protect revenue and customer experience.
CCD2 is the EU update to the framework for offering credit and deferred payment to consumers. It affects product design, sales, checkout and partnerships. Requirements include pre-contractual information via the SEKKI form, credit assessment, disclosure of costs and documentation that can be produced for review by the Swedish Financial Supervisory Authority (FI) or the Swedish Consumer Agency.
Planned application in Sweden is 20 November 2026. An effective plan includes gap analysis, role mapping and technical requirements early to ensure continuity. Leadership buy-in and awareness in steering groups should be established in good time across Europe.
The following are likely to be in scope:
- Invoices with extended payment terms
- Instalments and part-payment
- Leasing with purchase option in relevant cases
- Buy now, pay later options in checkout
When the company offers credit in its own name, sets the terms and takes the credit risk, for example for instalments or extended invoice terms. This triggers pre-contractual information and credit assessment, among other things. Evidential logging of decisions and disclosures is essential.
A business may become a credit intermediary when it presents third-party credit and is remunerated per transaction. Generally it does not take much to become a lender, and authorisation is then required. Roles should be assessed by a lawyer specialised in financial regulation based on your processes.
Typical BNPL designs are treated as consumer credit. Prioritise:
- Clear pre-contractual information at the right time
- Credit assessment and decision criteria
- Supplier agreements that allocate responsibilities
- Logs demonstrating what the customer saw and how decisions were taken
The Act clarifies pre-contractual information, credit assessment and how costs are communicated. Shorter deferrals and instalments are captured to a greater extent. The effect is that more flows are deemed credit and handled accordingly.
Yes, more may be subject to authorisation when intermediation occurs in own channels or when credit solutions are embedded. Common examples are e-commerce, marketplaces and actors integrating external invoice or pay-later services. The scope of authorisation depends on business model and role.
As more businesses fall under lending or intermediation, the number subject to Anti-Money Laundering (AML) requirements increases. This entails risk assessment, customer due diligence, reporting procedures and training. Coordinating consumer credit obligations with AML reduces duplication and strengthens internal control.
A practical package should include:
- Logs of pre-contractual information shown and terms accepted
- Documented credit assessment and decision criteria
- Traceable handling of withdrawal rights, complaints and reconsiderations
We deliver concrete advice and implementation support, for example:
- Gap analysis per product and flow with a prioritised action plan
- Role mapping between lender, credit intermediary and third-party provider
- Policies and pre-contractual information
- Training for sales, support and product teams, plus support in dialogue with the supervisory authority
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If you prefer phone, please feel free to contact Felix Morling at +46 70 444 42 85
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