CCD2: How Dutch Lenders Can Turn It to Their Advantage

As of mid-2025, the European Union’s revised Consumer Credit Directive (CCD2) is set to reshape lending across member states, including the Netherlands. CCD2 significantly expands the original 2008 directive (CCD1) by introducing new regulatory scrutiny over Buy Now, Pay Later (BNPL), deferred payment credit cards, and potentially private leasing products.

For Dutch lenders, both traditional banks and non-bank finance companies, this creates new compliance requirements and transforms the landscape for customer onboarding, affordability assessments, and competitive positioning. The changes are substantial, but so is the opportunity. CCD2 isn’t just about compliance, it’s a chance to modernize for long-term competitiveness.

Why CCD2 Matters for the Dutch Market

When CCD1 was introduced, it left many emerging consumer finance models unregulated. Since then, BNPL has surged in popularity, especially among younger demographics, while private leasing has become a mainstream alternative to car ownership.

CCD2 brings these models into the regulatory fold. BNPL providers and deferred payment card issuers will now need to perform mandatory income checks, report to the Bureau Krediet Registratie (BKR), and conduct age verification at origination.

Member states may also categorize private leasing as ‘consumer credit’, which would bring leasing providers under the same affordability, disclosure, and transparency requirements as traditional lenders. For fintechs and leasing startups that once operated with limited oversight, CCD2 represents a regulatory coming-of-age, and an end to regulatory arbitrage.

While the directive creates a level playing field, it does however also increase the operational burden for traditional lenders.

Compressed Timelines and High Stakes

The Dutch government published its CCD2 draft only in April 2025. That leaves a narrow window for implementation. EU member states must transpose CCD2 into national law by mid-2025, with enforcement expected to begin 12 to 18 months later. For the Netherlands, this suggests full implementation could begin as early as Q1 2027.

This gives lenders just under two years to redesign key aspects of their origination processes, particularly those tied to product eligibility, creditworthiness assessment, and regulatory disclosures.

This transition demands not only compliance, but agility.

The Impact on Dutch Lenders

New Compliance Burdens for Non-Bank Lenders

BNPL platforms and deferred payment card issuers must now become licensed credit providers. They will need to go well beyond soft credit pulls and basic age checks. Income verification, BKR reporting, and digital identity confirmation (e.g., DigiD) become mandatory.

For fintech lenders built around rapid, low-friction onboarding, this is a significant shift. Conversion rates may fall, margins could compress, and time to decision will rise, unless processes are redesigned for speed and compliance simultaneously.

Private Leasing, A Grey Area

If Dutch lawmakers classify private leasing as consumer credit, leasing providers will also face full credit assessments, disclosures through the Standard European Consumer Credit Information (SECCI) template, and registration as licensed institutions. This would require a significant evolution in how creditworthiness is determined and reported in the leasing space.

Many leasing firms today rely on inference based assessments, such as possession of a driver’s license as a proxy for age. These will no longer suffice. Flexibility will be key. Systems must support both leasing as finance and operational rental logic to accommodate regulatory ambiguity in the near term.

Intensifying Competition for Traditional Banks

As fintechs are brought under the regulatory perimeter, they gain the ability to expand their product suites into unsecured loans or more complex credit products. With real-time access to checkout and transaction data, they will be in a position to craft personalized credit offers that challenge traditional lenders.

Banks, in turn, must modernize. Siloed systems, and manual decisioning will not keep pace. Success will depend on real-time analytics, open banking integrations, and configurable affordability logic.

While CCD2 levels the playing field, it rewards speed, automation, and data fluency.

Rethinking Technology and Risk Infrastructures

CCD2 will place significant pressure on legacy systems, especially those with hard-coded origination workflows, manual underwriting, or disconnected data systems. Traditional batch processing will struggle to keep up with the volume and complexity of the mandated credit assessments.

This is a pivotal moment for Dutch lenders to rethink their risk architecture. Moving to a flexible, data-driven decisioning core is no longer optional. Without it, the cost of compliance could rise sharply, and competitive ground could be lost to more agile rivals.

Future-Proofing Lending Under CCD2

To stay ahead of CCD2 implementation, Dutch lenders should begin by auditing their existing origination workflows. Each product line - BNPL, credit cards, personal loans, and leasing - needs to be carefully mapped against CCD2’s new requirements for income verification, credit bureau reporting, age checks, and disclosure standards. This audit will help identify compliance gaps and highlight areas where modular system upgrades are required. Tools such as FICO® Platform support this process by enabling modular upgrades to onboarding workflows that align with CCD2’s compliance demands.

Next, lenders should adopt a rules-based decisioning framework that allows credit and risk policies to be updated dynamically as regulations evolve. Built-in capabilities such as real-time affordability scoring, risk segmentation, and scenario testing will be crucial, not just to ensure compliance, but to support smarter, faster lending decisions. Here, FICO® Platform enables dynamic credit policy updates and delivers built-in features, such as real-time scoring and risk segmentation, making it well-suited for regulatory shifts.

Data integration must also be modernized. Real-time access to income data, whether through open banking or secure APIs, will become essential. For customers with limited credit history, alternative data sources can help create a more accurate affordability picture. Integrating with the Bureau Krediet Registratie (BKR) for continuous exposure monitoring will also become a key compliance function.

FICO Platform can support secure API integrations and alternative data sources, making it easier to enrich affordability assessments while meeting data access and exposure monitoring requirements.

Given the uncertainty around how private leasing will be treated under CCD2, lenders in this space should prepare flexible workflows that can accommodate both leasing as finance and operational rental models. These workflows must be adaptable enough to align with the final legal interpretation once confirmed by Dutch regulators.

With FICO’s decisioning tools, lenders can configure adaptable workflows that accommodate different leasing classifications, ensuring readiness for evolving CCD2 interpretations.

Finally, design with flexibility in mind. Modularize onboarding and KYC/KYB processes so that individual components, such as identity verification, credit scoring, and fraud detection, can be upgraded or replaced without redesigning entire systems. This architectural flexibility will help lenders remain compliant and competitive as CCD2 continues to evolve.

The FICO platform’s modular architecture supports this flexibility, allowing individual components such as fraud detection or ID verification to be upgraded without major system overhauls.

Preparing for the Future

CCD2’s focus on responsible lending shouldn’t be seen as a challenge to growth. With the right analytics, lenders can still compete aggressively, balancing affordability with profitability. The key lies in optimizing credit limits and loan pricing at the individual customer level, without violating exposure constraints or fairness rules.

This is where an advanced decisioning tool, like FICO® Platform , becomes crucial. It allows institutions to test pricing and credit line strategies, forecast outcomes, and simulate the trade off between risk and reward.

CCD2 represents more than just another regulatory hurdle. It marks a shift in how credit markets operate and how consumer risk must be assessed in a digital first, data rich environment.

For Dutch lenders, this is a moment of truth. Those who act early, modernize strategically, and adopt flexible decisioning infrastructure will not only meet CCD2’s demands, but gain a lasting competitive edge.

Discover More Ways FICO Platform Can Improve Your Originations Strategies

• Download a complimentary copy of The Forrester Wave™: AI Decisioning Platforms, Q2 2025, Forrester Research, Inc., June 2025
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