Consumer Credit Directive (CCD2) (CCD2)

Consumer Credit Directive (CCD2)

Adopted, applies laterCCD2

Summary

It modernizes consumer credit rules. When creditworthiness assessment uses automated processing, consumers can request human intervention, a clear explanation and a review of the decision. Spain has not yet transposed it.

Who it applies to

Consumer lenders and credit intermediaries, including fintechs and buy-now-pay-later.

Penalties

Set by each Member State when transposing.

Official name: Directiva (UE) 2023/2225 del Parlamento Europeo y del Consejo, de 18 de octubre de 2023, relativa a los contratos de crédito al consumo
Official reference: Directiva (UE) 2023/2225, DO L de 30.10.2023; transposición hasta el 20.11.2025 y aplicación desde el 20.11.2026
Regulator: National credit and consumer authorities (Bank of Spain in Spain)
Official source: Check the sourceHow we verify sources

Key dates

November 20, 2025Transposition deadline
November 20, 2026National measures apply

Obligations and dates

Obligations table
Obligation	Article or citation	Status	Date	Who it applies to	Verification
Human intervention, explanation and challenge of automated scoring	Directiva (UE) 2023/2225, art. 18.5 y 18.8	Adopted, applies later	November 20, 2026	If you grant consumer credit and assess creditworthiness with models or AI. As a directive, it binds companies through national law: in Spain transposition is still pending and Parliament was dissolved on Oct 6, 2026, so the actual date in Spain may be later.	Verified in the official source on November 4, 2026

Human intervention, explanation and challenge of automated scoring

Directiva (UE) 2023/2225, art. 18.5 y 18.8Adopted, applies later

Applies from November 20, 2026

When it relates: If you grant consumer credit and assess creditworthiness with models or AI. As a directive, it binds companies through national law: in Spain transposition is still pending and Parliament was dissolved on Oct 6, 2026, so the actual date in Spain may be later.
What the rule provides: Allow consumers to request and obtain human intervention by the lender.
Give a clear, understandable explanation of the assessment, its logic and risks, and the main data used.
Allow consumers to express their view and request a review of the decision.
Do not use special categories of data or social media data to assess creditworthiness.
Typical evidence: Human review procedure and explanation letter templates.
List of data sources allowed in the model.
Related base documents: Automated Decision Review Procedure
Adverse Automated Decision Explanation Letter
Supporting documents: Model Risk Management Policy and Model Inventory
Automated Decision Log Standard
AI Complaints and Redress Procedure
Verification: Verified in the official source on November 4, 2026Checked in the Official Journal text (CELEX 32023L2225): Article 18(8) (human intervention, explanation, point of view and review), Article 18(5) (no special categories or social media data) and Article 48 (transposition by Nov 20, 2025 and application from Nov 20, 2026). The original text was reviewed, not the consolidated version. As a directive, it binds private companies through national law. Per secondary sources, the Spanish draft bill (Jan 7, 2026) was not adopted; not checked in the BOE.