On Jun. 22, 2026, Reg-Track made an editorial update to change the rule type to final.
Follows May 18, 2026, GE GVT published Law implementing EU Directive 2023/2225 on consumer credit agreements and regulating promotion of climate-neutral mobility.
Consumers will receive better legal protection when they carry out credit transactions.
So-called buy-now-pay-later models are also to be included in the consumer protection regulations for credit agreements for the first time; this is provided for in the draft law
Promotes European internal market for loans between entrepreneurs and consumers.
Requirements for creditworthiness checks, must be carried out before concluding contract, are to be tightened; aligned with standards re loans for real estate.
It goes back to Consumer credit directive, which will be implemented into German law.
Effectiveness
Interested parties may submit comments until Jul. 18, 2025; directive transposed into national law by Nov. 20, 2025, applied by member states from Nov. 20, 2026.
Jul. 2025 GE DK Opinion on Draft Bill
On Jul. 24, 2025, GE DK issued opinion on draft bill transposing CCD II Dir 2023/2225.
GE DK welcomed draft law as an important step towards digitalization and commitment to reducing bureaucracy, in particular the abolition of written form requirement in favor of digital solutions and goal of avoiding excessive regulation.
However, takes a critical view of proposed evaluation of an interest rate cap on overdraft facilities, as this could distort competition.
GE DK emphasized the importance of diverse range of terms and conditions as a sign of healthy competition.
GE DK calls for improvements in key areas, including legally secure contract changes to existing loan agreements; practical regulations on right of withdrawal, creditworthiness assessment, general terms and conditions amendment mechanism.
And clarifications on prohibition of tying, discrimination and residual debt insurance.
GE DK advocates a balanced, practical implementation that equally considers and strengthens digitalization, consumer protection and functioning competition.
Sep. 2025 Bill Adopted
On Sep. 3, 2025, GE JST published the GE GVTDraft law implementing Directive (EU) 2023/2225 on consumer credit agreements, with a questions and answers document.
The Directive's primary objective is to contribute to a high level of consumer protection and to promotion of the internal market for credit between businesses and consumers.
The new Consumer Credit Directive follows a full harmonization approach, which thus enables the member States of the European Union generally not to be allowed to then impose either stricter or less stringent consumer protection regulations than provided.
The implementation of the new Consumer Credit Directive will take place in particular through changes to the German civil code and Introductory act to German civil code.
The application of general consumer loan law will be expanded, the requirements for mandatory creditworthiness assessment prior to contract conclusion will be tightened, and existing requirements for real estate agreements will be applied to general loans.
Amendments implementing new Consumer Credit Directive are to apply Nov. 20, 2026, but changes to the German civil code will enter in force on day following publication.
The Bill will now complete its passage through the required parliamentary process in GE PRL, with any amendments to the text as required, before it will then be enacted.
Sep. 12, 2025 Digital Lending Reaction
On Sep. 12, 2025, GE BdB and GE DK said German banks and savings banks expressly welcome GE GVT proposal to abolish the written form requirement for consumer loans.
This change will allow loan agreements to be concluded entirely digitally in the future, securely, in a consumer-friendly way, and in line with the latest standards.
Emphasized that secure legal framework for consumers remain in place, as banking transactions (including granting of loans) may only be carried out with a license from GE BaFin, regardless of whether the loans are conducted digitally or in writing.
German Civil Code (BGB) also remains in place, says simply accepting a pre-selected acceptance option (check mark) in the contract is not enough to conclude a loan agreement, active declaration by customer explicitly confirming agreement needed.
Whether the contract is concluded digitally or handwritten on paper, protection provided by legal enshrined right of withdrawal for consumers is guaranteed.
Digital text has been standard for lending in many other European nations, now in GE.
Sep. 29, 2025 Bill To GE PRL
On Sep. 29, 2025, GE PRL received finalized draft law 21/1851 implementing Directive (EU) 2023/2225 on consumer credit agreements, with its justification and cover letter.
On Oct. 6, 2025, GE DK issued statement on draft law to implement Dir 2023/2225.
Bill is important step toward further digitalization, proposed abolition of written form requirements in favor of modern, digital methods is key and forward-looking measure.
However, it remains problematic that credit cards (especially charge cards), tolerated overdrafts will also be fully covered by new consumer credit regulations in the future.
In particular, comprehensive creditworthiness assessment will be required, even though this would not have been legally required.
Document dated Oct. 6, 2025, received from GE DK Oct. 14, summarized on Oct. 17.
Oct. 9, 2025 Updates
On Oct. 9, 2025, GE PRL informed that bill 21/1851 and bill 21/1847 on access to debt counselling services for consumers were referred to the Committee on Legal Affairs and Consumer Protection, following a half-hour debate during their first reading.
Oct. 17, 2025 Editorial Update
On Oct. 17, 2025, Reg-Track made an editorial update re GE DK statement of Oct. 6.
Nov. 2025 Public Hearing Update
On Nov. 3, 2025, GE PRL updated on a public hearing held by the Committee on Legal Affairs and Consumer Protection for the bill, during which MEPs, the banking sector, trade, consumer protection associations proposed many industry-specific amendments.
Including guidelines on tying and bundling transactions, more consumer-friendly lending practices, better waiting periods, specific referral rules, Civil Code changes.
Apr. 2026 GE PRL Approves Bill
On Apr. 17, 2026, GE PRL announced it had approved bill 21/1851 on the implementation of Dir 2023/2225 on consumer credit agreements.
The law will provide consumers with better protection when entering into general consumer loan agreements, and provide more consumer-friendly rules on termination protection and repayment.
Abolishes perpetual right of withdrawal which will create greater legal certainty for all parties.
In addition, consumers will get the right to human review where creditworthiness assessments are based on the automated processing of personal data.
GE PRL decided to exclude debit cards with deferred payment from legislation remit.
It also amended scoring provisions in the Federal Data Protection Act.
Finally, it adopted a funding rule for the Federal climate-neutral mobility for households with low and middle incomes programme; funding will generally apply to electric vehicles registered for the first time after Jan. 1, 2026.
Funding will also apply if the underlying purchase contract was concluded before the subsidy was applied for.
The aim is to prevent delays in purchases and ensure a streamlined, low-bureaucracy process through a single-stage funding procedure, where applications are submitted after the vehicle’s first registration.
In Apr. 2026, GE DK welcomed directive but said it is excessive in scope, see #294716.
May 2026 Federal Council Bill Approval
On May 8, 2026, GE GVT announced the draft law on improved consumer protection for loan agreements passed the Federal Council.
Improved consumer protection/expansion to include small loans, interest-free and fee-free loans, buy now, pay later loans strengthen consumers' rights re loan agreements.
Pre-contractual information obligations are being expanded; in the future, written form will suffice for concluding general consumer loans.
Objective limits for unconscionably excessive loan interest rates, developed by case law, are enshrined in law; period for revocation in the case of incorrect information should be limited to a maximum of twelve months and 14 days.
Further adjustments be made to competition/trade/supervisory/price indication law.
Bundestag amended the law to include a legal basis for subsidizing electric cars.
May 15, 2026 Mediation Committee
On May 15, 2026, GE PRL informed that the Bundesrat decided not to approve the law which required its consent, therefore GE GVT amended the law that was passed by the Bundestag, and called the Mediation Committee of the Bundestag and Bundesrat.
The Mediation Committee acts as an intermediary between the Bundestag and the Bundesrat; its task is to find a consensus between the Bundestag and the Bundesrat when bills passed by the Bundestag fail to secure a Bundesrat majority.
If the Committee's decisions differ from those of the Bundestag, a new vote in the Bundestag is required; if the Bundesrat approval is required for a law, the Bundestag and GE GVT can request the convening of the Committee to reach an agreement.
May 18, 2026 Legislation Published
On May 18, 2026, GE GVT published Law implementing EU Directive 2023/2225 on consumer credit agreements and regulating promotion of climate-neutral mobility.
Document dated May 18, 2026, was then received on Jun. 2 due to a fixed feed.
The Law, dated May 12, 2026, follows the previous GE GVT and GE PRL procedures.
The bulk of the Law enters into force on Nov. 20, 2026, but Article 1, point 6(c) and point 19; 2. Article 7, point 6, section 34l of the Trade Regulations; and 3. Article 15, all now enter into force on the day of publication of the legislation, on May 18, 2026.
Jun. 2026 Editorial Update
On Jun. 22, 2026, Reg-Track made an editorial update to change the rule type to final.
Follows May 18, 2026, GE GVT published Law implementing EU Directive 2023/2225 on consumer credit agreements and regulating promotion of climate-neutral mobility.
