Keep three dates distinct
The Directive separates transposition, application and repeal. Directive 2008/48/EC is repealed from 20 November 2026, subject to transitional provisions. A national launch plan therefore needs more than a single date in a calendar. Check the implementing legislation and its commencement provisions for the market concerned. Do not infer that national measures exist, are complete or are identical across Member States merely because the EU timetable is clear.
Use a transition inventory
Create an inventory of products, channels, intermediaries and existing agreement populations. For each item, record the relevant jurisdiction, agreement type, intended change date and open legal questions. Separate new originations from servicing of existing agreements. The inventory is a way to organise transition research; it does not decide which regime governs a contract. Assign unresolved questions to a named reviewer and attach the source needed to resolve them.
Test the cutover as a journey
A cutover can involve advertising, applications, decisioning, disclosure documents and agreement generation. Identify dependencies before choosing a release date. A new document version is not enough if an older application flow continues to deliver the previous version. Test an application begun before a release and completed afterwards, a delayed acceptance and a manually resumed application. Record the outcome and the assumption under which the test was assessed.
Preserve the basis for the change
Keep the national source, the interpretation approved for the product and the implementation record together. A transition log should identify the affected process, owner, release reference, test evidence and unresolved exceptions. Use the application date as a planning anchor while keeping market-specific legal questions visible. Avoid publishing a country status as complete until its legislation and current regulator material have been researched directly.
Primary sources
Directive (EU) 2023/2225: Articles 47–48 ↗Read the source in its current version. National implementing measures and product-specific applicability may require additional research.