# CCD2 Source: https://ordergroup.co/glossary/ccd2/ Last updated: 2026-10-10 > CCD2 (Directive (EU) 2023/2225) explained for lenders: scope, dates and what it changes in advertising, consent, credit decisions and arrears in your software. [Fintech](https://ordergroup.co/glossary/fintech/) 4 min read # CCD2 Consumer Credit Directive 2 Also known as: Consumer Credit Directive 2, Directive (EU) 2023/2225 Definition CCD2 is the common name of Directive (EU) 2023/2225 on credit agreements for consumers, which replaces Directive 2008/48/EC. Member States must apply the national rules implementing it from November 20, 2026. Cite this entry Text "CCD2". Order Group, Software glossary, 10 October 2026. https://ordergroup.co/glossary/ccd2/ HTML `CCD2 - Order Group` Reviewed by [Mateusz Widenka](https://ordergroup.co/authors/mateusz-widenka/), Head of Delivery Last reviewed 10 October 2026 ## How CCD2 works CCD2 is Directive (EU) 2023/2225 of October 18, 2023 on credit agreements for consumers, published in the Official Journal on October 30, 2023. It is a directive, not a regulation, so it works through national law. Under Article 48, Member States had to adopt and publish their implementing rules by November 20, 2025 and must apply them from November 20, 2026. Under Article 47, the old Consumer Credit Directive, 2008/48/EC, is repealed with effect from November 20, 2026, but it continues to apply to credit agreements that exist on that date until they end. The scope is wider than before. CCD2 excludes credit above EUR 100,000 (Article 2(2)(c)), except unsecured credit above that amount taken to renovate a residential property (Article 2(3)). There is no lower limit. Credit under EUR 200, credit free of interest and other charges, and credit repaid within three months with only insignificant charges are covered, although Member States may switch off a short list of provisions for them (Article 2(8)). Short deferred payments offered by the seller without a third party, free of interest and paid within 50 days of delivery, stay outside (Article 2(2)(h)); for online sellers that are not small or medium-sized enterprises the limit is 14 days. Most of the directive follows a customer journey. Advertising must carry the warning Caution! Borrowing money costs money or equivalent wording (Article 8(1)). Pre-contractual information goes on the Standard European Consumer Credit Information form, which must be legible and take into account the technical constraints of the medium (Article 10(6)). The lender must assess creditworthiness before the agreement (Article 18) and apply reasonable forbearance before enforcement (Article 35). ## What CCD2 means for your software Much of CCD2 lands in the product: screens, consents, the decision flow and the data behind them. Requirements for a lending system: - Advertising content must change without a release. The cost warning has to appear in every piece of advertising, including landing pages and calculators that promote credit, and where an electronic medium cannot show all the standard information clearly, part of it may sit behind a click, scroll or swipe (Article 8(6)). - The information form is data. It must be readable on a phone screen and consistent across channels, so render it from the offer data, not from a separate document that can drift. - No pre-ticked boxes. Default options, including pre-ticked boxes, do not count as consent to the credit or to ancillary services (Article 15). Tying is prohibited, bundling is allowed (Article 14(1)), so an add-on must be removable without blocking the application. - No credit without the customer's request. A pre-approved offer or a limit increase must wait for the customer's explicit agreement (Article 17). - Personalized prices are flagged. If the price was personalized through automated processing, the pre-contractual information says so (Article 10(3)(m)) and the customer is told clearly (Article 13). Store it as a field on the offer. - Credit decisions can be reconstructed. The lender documents its assessment procedures and the information used (Article 18(4)). When the assessment uses automated processing, the consumer can ask for human intervention: an explanation, a chance to state their view and a review of the decision (Article 18(8)). That needs a request path in the app, a review queue and a record of who changed what. - Customers in difficulty are found early. Lenders need processes to detect financial difficulty early (Article 36(2)) and must refer those customers to debt advice (Article 36(3)). Writing the specification? Add CCD2 to your requirements checklist Collect the terms your project touches and get their system requirements in one e-mail, ready for an RFP. CCD2 requirements and where they live in a lending system RequirementArticleWhere it lives Cost warning in advertising8(1), 8(6)Content managed outside the app releaseLegible information form across channels10(6)Offer data rendered per channelPersonalized price flag10(3)(m), 13Field on the offerNo pre-ticked consent; no tying14(1), 15Application and cross-sell screensNo unsolicited credit17Offer and limit-increase flowsDocumented creditworthiness assessment18(1), 18(4)Decision record with inputs and rule versionsHuman intervention after automated assessment18(8)Request path, review queue, audit trailReasonable forbearance before enforcement35(1)Arrears flows: extension, deferral, repayment planEarly detection and referral to debt advice36(2), 36(3)Signals in data, help path in the app ## Rules and regulation CCD2 also asks Member States to prevent excessively high borrowing rates, APRs or total costs of credit, for example with caps (Article 31(1)), and to report those measures to the Commission by November 20, 2026. The APR formula stays in place: Article 30 refers to Annex III, as described under [APR](https://ordergroup.co/glossary/apr/). As of October 2026, Poland has not published a new act implementing CCD2, and the Consumer Credit Act of May 12, 2011 is still in force. It already caps non-interest costs of credit (Article 36a) and requires a creditworthiness assessment before the agreement (Article 9). How the directive applies in a country without a national act is a legal question for your lawyer. Lenders that operate in several EU countries should expect different national versions of the same rules for some time. ## From our projects We have not run a CCD2 implementation project, and we do not describe the apps below as CCD2-compliant. They show where requirements of this kind land in a lending app. In the app we have built for AvaFin Poland since January 2026, AvaFin's central system decides the order of the loan application steps and the app displays them, so changing the order or scope of the steps does not need a new app version. Analytics and crash reporting start only after the app reads the customer's decision from the [consent management platform](https://ordergroup.co/glossary/consent-management/), so without a decision they stay off. Article 15 sets the same rule for credit: a default option is not consent. In Aasa24, the lending app we have built and developed for Aasa Polska since May 2023, Aasa's team changes calculator parameters, documents and messages in an admin panel, without a new release in the app stores. That is the layer where a changed cost warning or information text would be edited. ## Related terms - [APR](https://ordergroup.co/glossary/apr/) Annual percentage rate of charge In EU consumer credit law, the APR (annual percentage rate of charge) is the total cost of credit to the consumer expressed as an annual percentage of the total amount of credit. One EU formula is used to calculate it, so offers can be compared. - [Debt collection](https://ordergroup.co/glossary/debt-collection/) Debt collection is the process of recovering overdue payments from a borrower, from the first reminder after a missed due date through repayment plans and settlements to court and enforcement. The lender runs it itself or hands it to a collection agency or a debt buyer. - [Early repayment](https://ordergroup.co/glossary/early-repayment/) Early repayment is a consumer's right to repay all or part of a credit before the agreed date. EU law gives a matching reduction in the total cost of credit and caps the lender's compensation at 1% or 0.5% of the amount repaid early. - [Loan origination system (LOS)](https://ordergroup.co/glossary/loan-origination-system/) A loan origination system (LOS) is software that takes a loan from application to payout: it collects the application, verifies the applicant's data, supports the credit decision and issues the offer. After payout, a loan management system services the loan until it is repaid. ## Sources 1. [Directive (EU) 2023/2225 on credit agreements for consumers and repealing Directive 2008/48/EC](https://eur-lex.europa.eu/eli/dir/2023/2225/oj) - EUR-Lex 2. [Directive 2008/48/EC on credit agreements for consumers](https://eur-lex.europa.eu/eli/dir/2008/48/oj) - EUR-Lex 3. [Ustawa z dnia 12 maja 2011 r. o kredycie konsumenckim (tekst jednolity Dz.U. 2025 poz. 1362)](https://api.sejm.gov.pl/eli/acts/DU/2025/1362/text.pdf) - Sejm RP Mateusz Widenka reviewed this entry. Ask how it applies to your project. [Ask an engineer](https://ordergroup.co/contact-us/) ## FAQ ![Mateusz Widenka](https://ordergroup.co/media/images/T02DHCC1Z-U039G6G3JS1-8e7d2cd80ccb-512.format-webp.webp) Mateusz Widenka Head of Delivery [Talk to an engineer](https://ordergroup.co/contact-us/) ### When does CCD2 apply? Member States had to adopt their national rules by November 20, 2025 and must apply them from November 20, 2026 (Article 48). In countries that miss the date, the start depends on the national act. ### Does CCD2 apply to buy now, pay later? Interest-free credit and credit repaid within three months with only insignificant charges are in scope. Short interest-free deferred payments offered by the seller itself without a third party, paid within 50 days (14 days for online sellers that are not SMEs), are excluded. ### Does CCD2 replace the old Consumer Credit Directive right away? Directive 2008/48/EC is repealed with effect from November 20, 2026, but it keeps applying to agreements that exist on that date until they end. Some CCD2 rules also apply to existing open-end agreements. ### Does CCD2 require human review of automated credit decisions? If the creditworthiness assessment uses automated processing of personal data, the consumer can request human intervention: an explanation, a chance to give their view and a review of the decision (Article 18(8)). Building a system that depends on CCD2? See how we build software for this domain, with case studies and the stack we use. [See Fintech Software Development Services](https://ordergroup.co/fintech-software-development/) Requirements checklist For each term we send the definition and what it requires from your software. Free, no sales call needed. Your checklist is empty. Use the plus next to a term to add it.