Consumer Credit Directive 2.0 – More Consumer Protection, Higher Regulatory Burden? A View From Germany

RegCORE Client Alert | Banking Union | German Regulatory Developments

QuickTake

Directive 2023/2225 on credit agreements for consumers and repealing the Consumer Credit Directive (2008/48/EC) (referred to herein as CCD 2.0)¹ was published in the Official Journal of the EU on 30 October 2023 and came into force on 19 November 2023. EU Member States must adopt and publish laws, regulations and administrative provisions necessary to comply with CCD 2.0 by 20 November 2025 and CCD 2.0 will apply in full by 20 November 2026. While this might seem far off in 2024, CCD 2.0 sets out wide-reaching reforms and thus numerous changes for financial services firms, in particular creditors, credit intermediaries and their compliance. This applies both to their client-facing documentation as well as their internal systems and controls plus respective policies and procedures.