Interest rate, APR and total cost answer different questions
An interest rate is a component of credit pricing, while APR expresses the total cost of credit on a prescribed annualised basis and the total amount payable describes an aggregate repayment figure. These measures are not interchangeable. Advertising that highlights only a low nominal rate can give consumers an incomplete understanding when fees or mandatory costs materially affect what they must pay. Under the current EU consumer credit framework, Article 4 of Directive 2008/48/EC links cost-related promotional figures to standard-information requirements. Articles 7 and 8 of Directive (EU) 2023/2225 modernise the corresponding rules, with the national measures generally applying from 20 November 2026. Product scope and domestic law must be confirmed first.
Fixed and variable borrowing rates
A promotional rate needs to state whether the product uses a fixed or variable rate when that information is part of the prescribed advertising disclosure. A variable-rate product can have repayments that change in accordance with contractual provisions, so an example built solely on the first payment may not show the full pricing structure. Where promotional rates end after an introductory period, the reviewer should distinguish the initial conditions from those that follow. Ensure the underlying agreement supports the advertised claim and that the example uses the appropriate assumptions. The applicability of national rules may vary by credit type and the advertisement’s content; use the actual legal text rather than a universal marketing checklist.
Fees and compulsory ancillary services
Application charges, account fees, repayment administration fees and obligatory ancillary services can affect the cost of credit, depending on the relevant legal definitions and conditions. Some costs may be excluded from the statutory APR calculation, so a reviewer should not simply assume every fee is included or omitted. Article 8 of CCD2 includes provisions concerning ancillary services where they are necessary to obtain the credit or obtain it on the advertised terms. The information must reflect the legal treatment of the specific service. Marketers should obtain signed-off input from product and legal teams rather than independently selecting the lowest cost configuration. Changes in fee structures should automatically prompt reassessment of campaigns already online.
The importance of repayment amounts and credit duration
A small monthly payment can attract attention without revealing the total borrowing cost or the length of the commitment. Advertising reviews should assess whether the message conveys the actual duration, total repayable and instalment structure where the rules require them. An example using a different loan amount or term from the main offer can undermine comparability. For purchase financing, the cash price and any advance payment may also form part of the required standard information. Keep all numbers linked to the same version of the credit product. Review introductory offers, deferred first payments and balloon or residual obligations with particular care because they can alter how consumers perceive the offer.
How misleading impressions arise
A claim such as low interest, free finance or no hidden charges may be problematic if the actual agreement includes costs, conditions or eligibility limitations not apparent from the headline. Article 7 of CCD2 directs attention to communications that are fair, clear and not misleading, while Article 8 provides specific warning and information rules. A legally correct APR printed in a difficult-to-read note does not automatically cure a prominent misleading statement. Separate accuracy of arithmetic from accuracy of overall presentation. The practical review should compare the words used with contract terms, fee schedules and the full consumer journey. Be especially careful where merchant promotions combine purchase discounts with a credit offer.
Campaign controls and the transition to CCD2
Document each campaign’s creditor, product scope, target jurisdiction, borrowing-rate type, APR inputs, fee classification, total repayable figure, term and representative-example assumptions. Test public display across channels and devices and retain the final version with its approval date. A change of interest rate, fees, eligibility or national regulatory guidance requires a fresh review. Different jurisdictions can impose additional rules or restrictions, so an EU-wide template is not a substitute for country-level verification. Directive (EU) 2023/2225 is in force, but its implementing measures generally apply from 20 November 2026. Until that date, continue to apply existing national credit advertising and consumer-protection rules. Internal testing should consider more than whether individual figures add up. Reviewers can ask whether an ordinary consumer is likely to confuse a nominal percentage with the overall cost, whether fee descriptions correspond to their actual contractual meaning and whether repayment figures are anchored to the stated duration. Significant discrepancies between marketing and acceptance-stage terms should be logged and investigated. Documentation of these decisions allows a subsequent review when the legal position, product design or customer channel changes.
Frequently asked questions
Is the borrowing rate the same as APR?
No. APR reflects the legally defined annualised total cost of credit, not only the borrowing rate.
Must fees always be included in APR?
The inclusion of each cost follows the applicable statutory definition and prescribed assumptions.
What if a campaign runs in several countries?
Review the national law and regulator requirements for each targeted market.
Primary sources
Directive (EU) 2023/2225 ↗Directive 2008/48/EC ↗Read the source in its current version. National implementing measures and product-specific applicability may require additional research.