Status CCD II: Licence Application And Proportional Creditworthiness Assessment

On 6 October 2026, the House of Representatives approved the CCD II Implementation Act and adopted a number of motions in the process. In this article, we discuss the latest developments in the legislative process and the possibility of applying for a licence from the AFM.

For providers and intermediaries of consumer credit, the implementation of the revised Consumer Credit Directive (CCD II) brings about far-reaching changes. The AFM is already processing licence applications, and there is now greater clarity regarding the application of the creditworthiness assessment, particularly for providers of ‘buy now, pay later’ (BNPL) and other newly regulated forms of credit. In Implementation Act Consumer Credit Directive II and Implementation Decree CCD II and consultation on the commission rules for consumer credit, we had already discussed the key points of the draft legislation as it stood at that time.