The information must arrive before the consumer is bound
Under Article 5 of Directive 2008/48/EC, the creditor and, where applicable, the credit intermediary must provide the prescribed pre-contract information in good time before the consumer is bound by a covered credit agreement or offer. The timing is intended to let the consumer compare offers and decide whether to contract. It is not satisfied merely by making a document available after signature. Article 10 of Directive (EU) 2023/2225 retains the requirement, including for distance communication, and expressly addresses circumstances where information is provided less than one day before binding acceptance. As of October 2026, current national implementing law remains relevant; national measures for the revised Directive generally apply from 20 November 2026. The product, market, consumer and contractual acceptance event must be mapped before assessing compliance.
Good time depends on the actual decision journey
The legislation does not create a universally sufficient number of minutes for every credit product. The consumer needs a genuine opportunity to read the prescribed information and compare available offers. A process that displays a document immediately before the final acceptance button may raise questions even when the file technically opens. A longer and more complicated agreement, such as a variable-rate or multi-component finance product, may require more explanation than a straightforward offer. Operational reviewers should record the stages at which indicative terms become firm and when a consumer becomes bound. Any national guidance or case law concerning timing should be checked, rather than inventing an EU-wide minimum review period.
The less-than-one-day reminder under CCD2
Article 10 of CCD2 adds an express reminder mechanism when the prescribed information is supplied less than one day before the consumer becomes bound by the agreement or offer. The creditor or, where applicable, intermediary must send a reminder of the possibility of withdrawal and the procedure for withdrawal under Article 26. The reminder is sent between one and seven days after conclusion of the agreement or submission of a binding offer by the consumer, on paper or another durable medium. This is an additional obligation under the future national implementing framework, not a substitute for giving pre-contract information in good time. The exact triggering events, national wording and system delivery design need review against applicable implementing legislation.
Distance and digital acceptance create timing risks
Digital applications can combine advertising, product selection, identity checks, credit assessment, pre-contract information and agreement execution into one screen flow. Teams should identify whether pressing a button is only a request for an offer or the event that legally binds the consumer. A disclosure that appears after the binding action is too late for the general pre-contract duty. Investigate interrupted applications, returning customers, updated loan terms and multiple devices because a document displayed earlier may no longer describe the final offer. Record both the version delivered and the timestamp associated with the relevant contractual event. A timestamp is useful evidence, but it does not alone establish that content was clear, accessible and provided in good time.
Offers changing after disclosure need fresh attention
Information is supposed to reflect the terms offered and, where relevant, the consumer preferences and details supplied to the creditor. If the credit amount, rate, duration, fee schedule or ancillary service changes materially after a form has been delivered, reviewers should determine whether revised pre-contract information must be supplied before commitment. Do not rely on an outdated SECCI merely because it was delivered at an earlier stage. The nature of the amendment and the national legal framework determine the exact consequences. Procedures can compare the final agreement data with the last disclosure document, flag material mismatches and prevent an acceptance until the correct information is available. This is an operational control, not a claimed statutory software specification.
Evidence, controls and national implementation
A defensible record connects the application identifier, relevant legal regime, disclosure template, content version, delivery mechanism and contract event. Test sequences involving declined applications, revised pricing, resumption of abandoned checkouts and multilingual delivery. Where the business uses a merchant, broker or other intermediary, specify which participant delivers the document and how the creditor verifies performance. The revised Article 10 provisions should be added to an implementation timetable for 20 November 2026, while maintaining compliance with existing national requirements until the transition. Review triggers include regulator guidance, changes in electronic contracting, complaints about missing information and national amendments. A complete audit record assists investigation but must also comply with applicable data-protection and retention law.
Frequently asked questions
Does in good time always mean 24 hours?
No. The general requirement is to provide information sufficiently early; CCD2 adds a specific reminder mechanism when information is provided less than one day before binding acceptance.
Does a reminder replace pre-contract disclosure?
No. The Article 10 reminder is additional to the obligation to provide the required information in good time.
Do online agreements have the same timing principle?
Yes. Article 10 expressly includes distance communication within the duty, subject to applicable national implementation.
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.
Related research
consumer credit pre-contract information and disclosure requirements ↗