🎧 The new Consumer Credit Directive CCD2 tightens the requirements for creditworthiness assessments – listen in to find out what banks, fintechs and BNPL providers now need to consider. – Tune in now!
Creditworthiness assessments take centre stage under CCD2
In this episode of “Alles Legal – Fintech-Recht kompakt”, host Dana Wondra from Payment & Banking speaks with Dr Florian Lörsch, Partner at Annerton, about the new creditworthiness assessment requirements under the Consumer Credit Directive.
CCD2 is not just about mandatory information or checkout flows. It reaches deep into the processes providers use to assess whether consumers may be granted credit. This is particularly relevant for banks, fintechs and BNPL providers, where decisions are often made quickly, digitally and automatically.
What changes in the assessment standard
In future, credit decisions will have to meet a stricter standard. Credit may only be granted where it is likely that the consumer will be able to repay it in accordance with the contract.
This brings the standard for traditional consumer credit closer to the approach already familiar from residential real estate financing.
Scoring, data and proportionality
A key topic in the episode is practical implementation: Which data will providers have to collect? Will a score still be sufficient for smaller amounts? Or will providers need to ask for detailed information on income and expenses?
This is where the CCD2 principle of proportionality becomes particularly important. Especially for smaller credit amounts and digital checkout processes, the practical interpretation is likely to remain a point of discussion.
Automated decisions and new consumer rights
CCD2 becomes especially relevant where scoring models, algorithms or AI systems influence credit decisions. Consumers will receive new information and review rights.
Companies will need to explain more transparently how decisions are reached. They will also need to establish processes enabling customers to request human review.
Rejections, debt advice and BNPL
The episode also covers new obligations in the event of rejected credit applications, references to debt advisory services and the question of when a scoring model already qualifies as automated processing.
BNPL providers in particular should examine the new requirements early. CCD2 changes core processes in digital lending – especially where credit decisions are made directly at checkout.
About this podcast
Alles Legal – Fintech Recht Kompakt delivers sharp, weekly insights into legal and compliance matters in the world of banking. (in German only)
This podcast is a collaboration between Payment & Banking and PayTechLaw.
Each Wednesday, we unpack the legal developments shaping the financial world – clearly, concisely, and without the legal jargon.
Since 2021, PayTechLaw authors and Annerton attorneys have brought depth and clarity to complex topics.
Whether it’s PSD3, DORA, or FiDA – we provide the legal context you need.
In 20 minutes. No detours.
