Implementation Act Consumer Credit Directive II

The act to implement the revised Consumer Credit Directive (the Implementation Act) was published on 12 November 2025 and is currently before the Council of State for advice. The act differs in some respects from the version that was consulted on 15 April 2025. The Implementation Act implements Directive (EU) 2023/2225 on credit agreements for consumers (CCDII). In this news item, we discuss the most important changes to the existing legal framework for offering and provision of intermediary services in consumer credit.

The Implementation Act stipulates that forms of credit such as Buy Now, Pay Later (BNPL), credit cards and authorised overdrafts at banks will fall within the scope of the rules for credit offerors. This means that these forms of credit will also be subject to the legal safeguards that already exist for other types of consumer credit, including the licensing requirement, the obligation to carry out a creditworthiness assessment and affiliation with