EU Consumer Credit Directive II:
What It Means for Telcos
28 January 2026
The way European consumers access credit is evolving, and so are the rules. The European Union’s new Consumer Credit Directive II (CCD II), which comes into effect on 20 November 2026, is raising the bar on consumer protection, transparency, and responsible lending. This new legislation is designed to close the gaps, harmonise rules across the EU, and make sure everyone plays by the same rules.
What are the key changes?
In our recent webinar with the EU Commission and PwC, we discussed the impact of the new regulation and the practical implications for EU businesses.
If you are a retailer, telco or any company offering device financing, BNPL, deferred payments or bundled credit, even interest-free, CCD II applies to you. Here’s an overview of the key changes.
If you are a retailer, telco or any company offering device financing, BNPL, deferred payments or bundled credit, even interest-free, CCD II applies to you. Here’s an overview of the key changes.
Expanded scope
CCD II now covers a much wider range of credit products, including:
- Credit agreements from below €200 up to €100,000, including microloans, payday loans, and higher-value financing.
- Interest-free and deferred payment products (think BNPL and device financing), even if there’s no interest.
- Leasing agreements with an option to buy (e.g., leasing a device with a purchase option).
- Short-term credits, even those to be repaid within three months if there are fees.
- Bundled and ancillary offers, where credit is part of a package or comes with other services.
If you offer any form of consumer credit, even as a side service, CCD II likely applies to you.
Responsible lending and creditworthiness
No more “rubber-stamping” credit approvals. A creditworthiness assessment is vital to avoid irresponsible lending practices and over-indebtedness of consumers. This means:
- Credit providers must assess each consumer’s financial situation using relevant data (income, expenses, liabilities).
- Checks must be proportionate to the product, no unnecessary data collection.
- No use of sensitive or social media data in assessments.
If automated decision-making is used, consumers have the right to a human review and an explanation if credit is denied.
Enhanced pre-contractual information
Consumers need the facts, upfront and in plain language:
- Credit providers must deliver the Standard European Consumer Credit Information (SECCI) form in a consistent format.
- Essential info goes on the first page for easy comparison, even on mobile.
- Pre-contractual information must be provided well before signing. If it’s less than a day in advance, a reminder about the right to withdraw is required.
- Providers must offer clear explanations to help consumers assess if the product fits their needs.
Ban on tying practices
- No more forcing consumers to buy bundled products.
- Credit agreements can’t be tied to other products or services unless strictly necessary (e.g. mandatory insurance).
- If insurance is required, consumers get at least three days to compare offers.
- No pre-ticked boxes, consent must be explicit.
- No unsolicited credit offers or pre-approved cards.
Stronger enforcement and licensing
- Only authorised, accountable businesses can offer consumer credit:
- All credit providers and intermediaries must be authorised or registered with national authorities.
- SMEs may be exempt if they only offer ancillary, interest-free credit with minimal late fees, but large enterprises can’t use these exemptions.
Harmonisation with local flexibility
CCD II harmonises the core rules but leaves some flexibility for member states, especially for low-risk or short-duration products. Keep an eye on local developments.
Watch the full webinar
If you are interested in learning more, check out our recent webinar with Dr. Daniela Bankier of the European Commission. Along with our partner PwC, we discuss practical implications of the new legislation and how telecom providers can future proof their consumer credit offerings.
Start planning now
Ready to transform compliance into a competitive advantage? Mambu’s composable platform, along with our expert partner ecosystem, can provide you with the technical agility to manage new regulatory requirements with ease.
Contact us today to learn more about how our proven technology has helped telco businesses launch compliant, scalable lending solutions.
Contact us today to learn more about how our proven technology has helped telco businesses launch compliant, scalable lending solutions.
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