Start with the product and the law that applies
Before a consumer enters a covered credit agreement, the creditor and, where relevant, the credit intermediary must supply information enabling the consumer to compare offers and understand the proposed commitment. In the European Union, Article 5 of Directive 2008/48/EC forms the basis of pre-contract information duties under applicable national implementing laws for many existing covered products. Directive (EU) 2023/2225 revises the framework. Its Article 10 requires clear and comprehensible pre-contract information in good time before the consumer becomes bound, with national measures generally applicable from 20 November 2026. Neither Directive is a substitute for checking national implementing legislation, exceptions and product classification. Start with the product, parties, country and date rather than choosing a disclosure template from its marketing name.
Identify the agreement and the responsible businesses
The first information group identifies the type of credit, the creditor and, where applicable, the intermediary. Relevant terms include the total amount of credit, conditions for accessing funds, agreement duration and the particular goods or services financed where the transaction involves deferred payment or linked credit. The names on a retailer's checkout screen may differ from the actual creditor. A disclosure should reflect the legal relationship and its contractual terms, not merely the organisation whose logo appears most prominently. For a digital lending journey, teams should document the point when a consumer becomes bound and which business supplies the information at that point. The fact that a merchant distributes the form does not automatically relieve the creditor of its legal duties.
Explain interest, APR, payments and all relevant charges
A consumer needs understandable information about the borrowing rate and its conditions, the annual percentage rate of charge, the total amount payable and the number, amount and timing of repayments, as applicable. Relevant costs may include account maintenance, payment instruments and compulsory ancillary services under the legal rules governing the calculation. A nominal interest rate is not interchangeable with the APR, which represents a prescribed annualised measure of credit cost. For variable rates, the disclosed mechanism, reference rate and adjustment conditions can be important. Information about missed-payment charges and consequences also belongs within the statutory disclosure scheme. Every figure should be computed using the terms actually offered, with assumptions recorded where the prescribed calculation needs them.
Tell consumers about important rights and risks
The pre-contract stage also covers matters beyond price. Depending on the applicable agreement and legal framework, the consumer may need information about security, compulsory insurance or other ancillary services, withdrawal, early repayment and any permissible early-repayment compensation. The information about late payments should not be reduced to a single fee if further consequences are relevant. Under the earlier EU framework, Article 5 sets out a detailed list of information and points to the Standard European Consumer Credit Information form in Annex II. CCD2 Article 10 and Annex I reorganise the requirements and make key elements prominent. Certain special agreements covered by Article 11 use a different form. Accurate classification prevents both omissions and unnecessary use of the wrong statutory template.
Provide information before the consumer is bound
The timing matters as much as the list of data. Under Article 5 of Directive 2008/48/EC and Article 10 of CCD2, pre-contract information is to be supplied in good time before the relevant binding commitment, subject to the governing regime. That is not necessarily the moment a borrower first visits a comparison site, nor may it be postponed until after accepting an agreement. The information is provided on paper or a qualifying durable medium, under the applicable provisions. CCD2 additionally provides for a reminder about withdrawal where the pre-contract information is supplied less than one day before the consumer becomes bound, under the conditions in Article 10. A temporary on-screen message should not automatically be treated as satisfying durable-medium requirements.
Check forms, delivery evidence and national differences
A practical compliance review compares every prescribed field with the product's pricing system, contractual terms and customer journey. Preserve the offer version, calculations, disclosure language, document supplied and a reliable record of when the consumer received it. Test amended offers, interrupted online applications, assisted sales and small mobile screens. Where the customer changes the borrowing amount or term, establish whether the information must be recalculated and provided again before binding acceptance. Adequate explanations under the applicable legal framework are related to, but distinct from, delivering information. The EU transposition deadline for CCD2 was 20 November 2025; application is generally from 20 November 2026. Continue checking current national requirements and later regulator guidance before treating a product journey as compliant.
Frequently asked questions
Is the same disclosure document required for every EU credit product?
No. Product scope, agreement classification and applicable national law determine the prescribed form and its contents.
When does CCD2 replace the previous framework?
Member States must generally apply their CCD2 implementing measures from 20 November 2026, subject to the applicable transitional provisions.
Is providing a form the same as giving adequate explanations?
No. Information delivery and the legally required explanations are distinct obligations and should be assessed separately.
Primary sources
Directive 2008/48/EC: Article 5 and Annex II ↗Directive (EU) 2023/2225: Articles 10 to 12 and Annexes I and II ↗Read the source in its current version. National implementing measures and product-specific applicability may require additional research.
Related research
consumer credit pre-contract information and disclosure requirements ↗