CCD2 and Overdraft Facilities: New Obligations for Banks | ALLES LEGAL #136

🎧 The new Consumer Credit Directive (CCD2) will significantly reshape established banking products. In the latest episode of “Alles Legal – Fintech-Recht kompakt”, Dr Florian Lörsch from Annerton explains the new obligations banks will face regarding overdraft facilities and tolerated overdrafts – and why institutions should start restructuring their lending and account processes now. – Tune in now!

Podcast: https://paymentandbanking.podigee.io/834-alles-legal-136-ccd2-bei-dispo-und-uberziehung-diese-neuen-pflichten-kommen-auf-banken-zu/

New CCD2 Rules for Overdraft Facilities

CCD2 does not only affect traditional consumer loans and buy-now-pay-later models. Overdraft facilities will also become subject to significantly stricter regulation. In this episode, host Dana Wondra speaks with lawyer Dr Florian Lörsch about the practical implications for banks and fintech companies.

Under the new rules, banks will face enhanced information obligations. Customers must be informed at least monthly about balances, interest and repayments, replacing the previous quarterly information requirements.

Stricter Termination and Repayment Requirements

The directive also introduces new rules for terminating or reducing overdraft facilities. The notice period is now two months. Banks also will be required to notify consumers at least 30 days in advance before terminating or reducing an overdraft limit.

In addition, institutions must allow consumers to repay outstanding balances in twelve equal monthly instalments. As a result, overdraft facilities will increasingly be treated like regular consumer loans from a regulatory perspective.

Creditworthiness Assessments Become More Comprehensive

CCD2 also significantly tightens creditworthiness assessments. According to the explanatory memorandum accompanying the directive, banks will need to assess whether consumers would be capable of repaying a terminated overdraft facility within twelve months.

This marks a major shift away from simple salary-based models towards more comprehensive analyses of consumers’ income and expenditure.

New Obligations for Tolerated Overdrafts

The reform also affects tolerated overdrafts. Banks will need to identify earlier whether customers regularly or permanently exceed their account limits and adapt their monitoring and compliance processes accordingly.

The episode demonstrates how profoundly CCD2 will impact even long-established banking products and why banks and fintechs should start preparing their operational processes now.

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.



By continuing, you accept our privacy policy.
You May Also Like
Virtuelle IBANs im Visier Was die neue Bafin-Aufsichtsmitteilung für Banken und Zahlungsdienstleister bedeutet Virtual IBANs under BaFin scrutiny: New AML expectations for banks and payment service providers
Read More

Virtual IBANs under BaFin scrutiny: New AML expectations for banks and payment service providers

Virtual IBANs have become an established component of modern payment models. With Supervisory Notice 06/2026, BaFin now clarifies its expectations for credit institutions and payment service providers regarding transparency, anti-money laundering compliance and risk management in complex virtual IBAN structures.
Read More
EuGH schafft Klarheit: Nicht jede Weiterleitung von Geldern Dritter ist ein Zahlungsdienst im Sinne der PSD2 ECJ Clarifies the Scope of PSD2: Not Every Transfer of Third-Party Funds Constitutes a Payment Service
Read More

ECJ Clarifies the Scope of PSD2: Not Every Transfer of Third-Party Funds Constitutes a Payment Service

The ECJ has further clarified the distinction between payment services and other business models. The judgment confirms that merely receiving and forwarding third-party funds does not automatically trigger licensing requirements under PSD2. The decision provides greater legal certainty for FinTechs, platform operators and other businesses handling payment flows, while emphasising that the specific business model remains decisive.
Read More