The EU’s Consumer Credit Directive 2 (CCD2) is set to shake up business as usual; not just for the BNPL market, but for all European lenders. In recent years, European regulators have shown their teeth in doling out fines. In 2023, crypto and digital payment companies paid $5.8 billion in fines due to poor customer checks and AML controls. The CCD2’s penalty structure exposes lenders to fines of up to 4% of their annual turnover per market, for widespread violations.
Meeting CCD2’s affordability and verification requirements at scale requires real-time access to financial data, which is exactly what Open Banking offers. With providers increasingly offering faster integration times, Open Banking is becoming an attractive option for businesses aiming to avoid penalties and be CCD2 compliant by the November deadline.
The Context and Thought Behind CCD2
CCD2 comes in the context of a broader regulatory push in the European Union. PSD3/PSR has now been finalised, while FiDA continues to move through the EU legislative process. Taken together, lenders are facing significant regulatory pressure that will reshape their core business. But here’s the thing: CCD2 compliance isn’t just a legal box-ticking exercise. Forward-looking lenders are investing in Open Banking infrastructure that turns compliance into a competitive advantage. Qwist’s Open Banking solutions are built to meet that exact standard, allowing lenders to move fast without compromising on compliance.
At the heart of CCD2 is a push by European regulators to improve consumer rights in digital financing. The BNPL companies that rapidly expanded during a decade of relatively light EU regulation are now subject to mandatory affordability checks on all non-mortgage credit up to €100k. The most innovative businesses like Younited that reached profitability while expanding instalment credit across France, Italy, Portugal and Spain have already started adapting their processes in order to meet CCD2’s new affordability requirements. As the market consolidates, the question for lenders is not about whether to invest in compliant infrastructure, but how quickly they can do it.
The Market Already in Motion
The BNPL market has already started adapting to offset the margin pressures caused by CCD2 compliance. From fast fashion purchases under €200, BNPL lenders are now favouring high-value products like solar panels, EV chargers and furniture. Scalapay, whose recent €70 million EIB investment is accelerating its expansion across 10,000+ brands in DACH, Iberia, and Belgium and the Netherlands, represents exactly the high-growth BNPL provider for whom CCD2 compliance is the next big opportunity. Higher fixed costs are also causing market consolidation. As small BNPL lenders struggle to turn a profit while building a compliant tech stack, larger platforms are swooping in and acquiring smaller BNPL lenders.
According to Deloitte, banks are uniquely positioned to capitalise on the CCD2 shake-up, as they already operate within a regulated framework and have access to customer data. Major banks are starting to offer their own BNPL products directly in their banking apps, via BNPL credit cards and embedded merchant checkouts. The trend is already playing out with tier 1 banks across Europe. In 2025, J.P. Morgan provided a €100 million debt facility to B2B BNPL provider Mondu and added them to its Partner Network, enabling the bank to offer Mondu’s installment solution directly to its corporate clients.
Nevertheless the disruption doesn’t only affect BNPL providers, CCD2 affects all lenders. Insurance, lines of credit and car loans all fall under CCD2 and legacy credit checks won’t be compliant. For car loan providers like Ibancar, whose model delivers financing within hours and without direct borrower contact, CCD2 means redesigning the frictionless experience around compliant affordability checks. The stricter identity verification and affordability requirements are also reshaping the fraud prevention space. For providers like FraudNet, whose solutions are built around real-time financial data, CCD2 raises the bar on the quality and speed of the data that underpins their fraud checks. The common thread between these sectors is the same: static, backward-looking data is no longer sufficient.Traditional credit bureau scores, including those from established agencies like Schufa, provide a snapshot in time that falls short of CCD2’s requirement for real-time affordability assessments. A credit score tells you what a borrower’s financial history looked like. Open Banking data tells you what their financial position is today.
How Qwist Delivers CCD2-Compliant Infrastructure
CCD2 requires lenders to gain a more sophisticated picture of a customer’s creditworthiness. It moves beyond a traditional credit score, requiring a real-time view of income, spending habits and repayment capacity. Open Banking infrastructure is becoming essential for lenders that need scalable, real-time affordability assessments across multiple European markets. Qwist’s Open Banking solutions are built to meet that exact standard, allowing AIS connectivity, data enrichment and risk intelligence solutions that enable CCD2-compliant and efficient lending processes.
Income Verification and Affordability Assessment
Qwist’s Income Verification provides lenders a real-time view of their customer’s income and disposable income at the point of sale. Rather than relying on manual bank statement uploads, or self-reported figures, which fall short of CCD2’s affordability standard, lenders get verified, categorised income data automatically. This creates faster credit decisions, fewer manual processes and CCD2-compliant affordability assessments. For the end user, it offers faster access to credit, allowing them to focus on the purchase, not the process.
Spending Analysis and Financial Behaviour Insights
Going beyond simple income verification, the Income and Risk Reports provide a detailed picture of a borrower’s actual financial behaviour, recurring payments, discretionary spending patterns, and indicators of financial stress. Using these insights, lenders can confidently approve customers, while maintaining compliance. For borrowers, this means fairer decisions based on their actual financial position, not just a static credit score.
Fraud Detection and Risk Scoring
Raw banking data becomes a clean, categorised data set through Qwist’s Data Enrichment, giving lenders the risk intelligence they need to identify issues that legacy systems miss.
All three capabilities are accessible with a single API integration, covering multiple markets from one connection. For lenders navigating the fragmented national implementation of CCD2 across Europe, Qwist Link provides access to Open Finance data within 48 hours, removing engineering overheads that slow adoption.
Boost Customer Conversion with CCD2 Compliance
Businesses that have fully integrated Open Banking into customer creditworthiness processes are positioned to boost the speed and volume of lending decisions. The BNPL providers already treating compliance as a growth lever are pulling ahead. Unzer, which serves over 85,000 merchants across the EU, has launched a dedicated project, handling creditworthiness assessments for their merchants so they don’t have to. By providing a more nuanced credit assessment powered by Open Banking, lenders build customer trust through transparent terms at the point of sale and by approving credit repayments that customers can actually meet.
Post-CCD2, the lending space will shift from one-click purchases with hidden terms, to a more transparent market. The winners won’t be those who are most compliant, they’ll be those who use compliance infrastructure to build faster, safer and more transparent user experiences.
Want to learn how Qwist can make you compliant before the CCD2 November deadline? Reach out to our sales team today.
