Consumer Credit Directive 2 (CCD2) – What consumer lenders in Ireland need to know

The new Consumer Credit Directive (Directive EU 2023/2225) (CCD2) represents the most significant overhaul of the EU consumer credit framework in over a decade since the publication of Directive 2008/48/EC (CCD1), which is repealed and replaced by CCD2.

CCD2 places renewed emphasis on responsible lending and fair treatment of consumers across the customer journey, from advertising and disclosures to creditworthiness assessments and arrears management. At the same time, CCD2 addresses evolving market practices and reflect today’s digital lending landscape. As a result, the changes translate into significant operational uplift for consumer credit providers, who will need to ramp up implementation efforts as the 20 November 2026 deadline approaches.

The revisions to the EU consumer credit framework were needed to:

• keep pace with evolving consumer credit products, changing consumer behaviour and technological developments
• address fragmentation and inconsistent application of rules arising from diverging Member State approaches to CCD1 implementation
• boost the cross-border consumer credit market

The reforms are wide-ranging and consumer credit providers will need to operationalise the enhanced consumer protections across an increasingly digital customer journey, addressing areas such as:

• advertising and marketing
• pre and post-contractual information
• customer documentation
• credit worthiness assessments
• forbearance measures
• bundling and prohibited tying practices
• advisory services
• right of withdrawal
• staff competence and remuneration

Implementation will be all the more challenging for providers who currently offer consumer credit products that are newly brought within the scope of the revised framework, e.g.:

• micro-loans
• hire-purchase agreements and leasing agreements
• interest-free credit, certain short-term / deferred credit
• deferred debit cards
• all authorised overdrafts
• crowdfunding credit services

All consumer credit providers should expect implementation to require coordinated input from across their businesses, working under a prescriptive compliance project to ensure the impacts of the reforms are fully identified and appropriately addressed. The compliance project plan will need clear internal milestones and accountability for delivery. It should begin with a comprehensive scope-mapping exercise to ensure all products newly brought within the revised framework are captured. The project plan should also incorporate updates across several compliance areas, such as customer information and documentation, customer notifications, policies, procedures, systems and controls.

To date, Ireland has not published transposing legislation despite the transposition deadline of 20 November 2025, but we expect the transposing legislation to closely mirror the wording of the CCD2 text and there to be no gold-plating.

For information on how ALG can assist your business with CCD2 implementation, please contact Eoin O’Connor, Partner, Eimear O’Brien, Partner, Patrick Brandt, Partner, Louise Hogan, Partner, Sarah Lee, Senior Practice Development Lawyer or your usual ALG contact.

Date published: 7 May 2026