CCD2: Transposition still lagging across Member States

With less than five months until the revised Consumer Credit Directive (CCD2) becomes applicable on 20 November 2026, transposition remains uneven. While a third of Member States have adopted, or substantially completed, their national legislation, the majority have yet to finalise this process, or start it in earnest, despite a deadline of 20 November 2025. Consequently, lenders are left with little time to deliver significant operational change, and in some markets must act without knowing the final rules. As a directive, CCD2 leaves considerable room for national divergence, granting Member States policy choices in more than 20 separate areas. 

The Commission maintains that the application date will not move and continues to press Member States to complete their legislative processes. It initiated the first steps in infringement proceedings against 23 Member States that missed the transposition deadline earlier in 2026, though these proceed at the Commission's discretion and on lengthy timelines. 

In June, Eurofinas met the Commission to discuss the practical challenges facing lenders as the application date approaches. Discussions centred on the need for legal certainty around creditworthiness assessments, customer journeys and other operational requirements where national legislation or supervisory guidance remains outstanding.  

Eurofinas remains engaged with the Commission and national authorities to promote the proportionate and consistent implementation of CCD2, delivering consumer protection while remaining operationally workable across different products and business models.