On 19 November 2023, Directive (EU) 2023/2225 on consumer credit agreements ('CCD II') entered into force. One of the main objectives of CCD II is to balance the advantages of digitisation in facilitating access to consumer credit, with lending practices that violate consumer interests.. The key issues addressed in CCD 2 IIo BNPL services, the content of consumer credit advertising and the regulation of consumer credit cost limits. The Directive provides for as many as 20 national options that can be used by the Polish legislator. CCD II is to be implemented into Polish law by 20 November 2025 and the application of the implemented provisions by 20 November 2026.
- Why us?
As a leading financial regulation law firm, we support our clients providing consumer credit services at every stage of their operations - from legal support for product design, through implementation, to ongoing regulatory support. Our experience includes carrying out bespoke projects for some of the largest players in the market.
- Who are we helping?
Banks, lending institutions
- How can we help?
- Support in the development, adaptation and implementation of policies, procedures and other internal documentation with CCD II and the Polish regulations implementing it;
- Support in the development, adaptation and implementation of new products compliant with CCD II and the Polish regulations implementing it;
- Assistance in determining whether new licenses are required or whether existing licenses need to be extended;
- Training for clients and their staff to ensure a comprehensive understanding of CCD II regulations;
- Guidance on the identification and management of risks associated with CCD II and the Polish regulations implementing it;
- Conduct audits and due diligence to assess the client's current state of compliance and identify areas for improvement following the entry into force of CCD II and the Polish regulations implementing it;
- Supporting clients in navigating the complexities of cross-border service provision while ensuring compliance with CCD II and Polish regulations implementing it;
- Establish systems to monitor regulatory changes and provide timely updates to ensure ongoing compliance;