New consumer credit rules under CCD2 - what will change for borrowers?
If you are planning to take out a personal loan, an instalment loan or buy-now-pay-later financing, you should know that the EU Consumer Credit Directive 2 (CCD2) fundamentally reshapes the rules for consumer lending across the entire European Union, and Poland is in the process of implementing it into national law. The new regulations mean more rights for borrowers, greater transparency in offers, and new obligations for banks and loan companies.
Below I explain point by point exactly what is changing, what you can demand from financial institutions, and how the new rules will affect comparing credit offers in Poland.
Where does CCD2 come from, and what is the status of implementation in Poland?
CCD2 (Directive 2023/2225) replaces the old Consumer Credit Directive from 2008. The European Parliament and the Council of the EU adopted it in October 2023, setting member states a deadline of 20 November 2025 to transpose it into national law, with the rules due to actually apply from 20 November 2026. Poland missed the original transposition deadline - a new Consumer Credit Act (drafted by UOKiK, known as bill UC82) was still going through consultation and inter-ministerial review during 2026.
Update (16 October 2026): as far as can be confirmed, the new Polish law implementing CCD2 had not yet entered into force. The European Commission sent Poland a formal notice over the missed transposition deadline, and the draft law was still under government review in mid-2026. The target date for the rules to apply across the EU, including Poland, is 20 November 2026 - until then, the existing 2011 Consumer Credit Act remains in force. The changes described below refer to the text of the CCD2 directive and the draft Polish law; check the current status with UOKiK before making financial decisions based on it.
The reason for the delay was prosaic: the scope of the changes turned out to be very broad. The new law is meant to cover not only banks but also credit unions, non-bank lending companies (payday lenders), buy-now-pay-later (BNPL) platforms, and credit intermediaries. Consultations with the financial and lending sector took considerably longer than planned.
What does CCD2 specifically change - 7 key changes
1. Broader scope - BNPL and interest-free loans now regulated
This is one of the biggest novelties. The old directive covered loans from €200 to €75,000. The new one covers practically all consumer loans, including:
- Buy Now Pay Later (BNPL) services offered by e-commerce platforms.
- Interest-free loans if the consumer bears any other costs.
- Short-term loans (payday loans) that previously benefited from exemptions.
- Loans granted by an employer to an employee at below-market rates.
In practice, a BNPL platform operator must now verify your creditworthiness before providing financing - even if you are buying a jacket worth 300 zloty on instalments. This is intended to limit excessive debt in the online shopping segment.
2. Mandatory creditworthiness assessment - expanded debtor databases
The new rules oblige lenders to conduct a thorough creditworthiness assessment before granting any loan. The assessment must be based on sufficient, up-to-date and reliable information, not just the client's declaration. Lenders must check debtor databases - mandatory, not optional.
If a bank fails to conduct a proper assessment, the consumer can invoke this fact in a dispute. The new rules explicitly prohibit granting a loan when the analysis indicates the consumer cannot repay it.
3. Personalised SECCI information sheet - one format for the entire EU
Before signing a credit agreement, the bank or loan company must provide you with the Standard European Consumer Credit Information document (SECCI). It must now contain:
- The total cost of credit expressed in zloty (not just as a percentage).
- APR - Annual Percentage Rate, calculated using a new unified method across the EU.
- A warning about the consequences of non-payment and the right to early repayment.
- Information about the right to a reflection period (at least 1 working day).
- Clear information on whether the offer is personalised based on algorithmic profiling.
The last point is entirely new. If the bank uses an algorithm to determine your offer (for example, a higher interest rate based on your purchase history), it must inform you. You also gain the right to an explanation of how the algorithm assessed your application.
4. Right to a reflection period - minimum 1 working day
Before signing a credit agreement, you now have a guaranteed minimum 1 working day to consider your decision. The bank cannot pressure you into signing immediately. This is particularly important for loans sold in shops (for the purchase of home appliances, furniture or computer equipment), where sales pressure was previously very high.
5. Right to early repayment - reduced compensation for the bank
CCD2 changes the rules for calculating the bank's compensation for early repayment. The new rules specify that compensation cannot exceed the actual costs incurred by the lender as a result of early repayment, and must be documented. Banks can no longer apply simple flat-rate early repayment fees without justification.
6. New obligations on debt restructuring
If you have trouble repaying your loan, CCD2 places new informational and support obligations on banks. The lender must:
- Inform you about restructuring options before referring the case to debt collection.
- Offer at least one restructuring option tailored to your situation (e.g. extending the repayment period, capital repayment moratorium).
- Refer you to free debt counselling services.
7. Ban on commission-based remuneration for intermediaries
The new rules prohibit systems for remunerating credit intermediaries (financial advisors, shop agents) that incentivise selling more expensive products to the detriment of the client. A bank cannot pay an intermediary a higher commission for selling a loan with a higher interest rate or longer repayment period.
What this means for you practically - comparing loans after the changes
The new rules make comparing credit offers easier and more reliable. APR calculated by a uniform method across the EU, a standardised SECCI sheet, and the obligation to disclose personalised algorithmic offers - all of this works in your favour.
Use our personal loan comparison to see current offers from banks and non-bank lenders side by side. Remember that the SECCI sheet is already required today, and its scope will expand once the new law implementing CCD2 takes effect (application is planned from 20 November 2026) - either way, you have the right to demand an up-to-date SECCI sheet before signing anything.
If you are planning larger expenditures and are considering mortgage financing, also check our mortgage loan comparison. CCD2 does not apply here (mortgages are governed by a separate directive, MCD), but it is worth knowing the difference between the products.
Does CCD2 cover mortgages and peer-to-peer loans?
No. CCD2 covers only consumer credits - those for purposes unrelated to business or professional activity, generally up to €100,000. Mortgage loans are regulated by the separate Mortgage Credit Directive (MCD), and peer-to-peer loans remain outside the scope of CCD2.
Business loans are also excluded - if you run a company and are looking for business financing, check our business account offers, where you will also find links to credit products for entrepreneurs.
How to check whether your bank is complying with the new rules
Above all, check whether you received the SECCI sheet before signing any agreement. If the bank or loan company skips this step, you have the right to complain and can report the matter to the Office of Competition and Consumer Protection (UOKiK) or the Financial Ombudsman.
Also check whether the APR is stated clearly - not just in footnotes in small print, but in the main body of the agreement and in advertising materials. The new rules prohibit hiding key costs.
Summary - what to remember from CCD2
CCD2 is one of the most important changes to the consumer credit market in over a decade. For the average borrower, four things matter most:
- You have the right to a SECCI sheet before signing any credit agreement - demand it and read it carefully.
- You have the right to at least 1 working day to consider your decision - do not be rushed.
- You have the right to early repayment with a documented, justified fee - not a flat-rate commission.
- BNPL services are now subject to the same rules as bank loans - the operator must check your creditworthiness.
Before signing any credit agreement, compare offers from several institutions. Use our personal loan ranking to see which banks currently offer the best terms. Knowledge of the new rules is your negotiating advantage - use it.