Key changes
- Extended scope: CCD2 now applies to a broader range of credit products, including short-term and low-value loans as well as BNPL offerings.
- Enhanced pre-contractual and contractual transparency: including more detailed and standardized information for consumers to improve consumer understanding and comparison.
- Tighter rules on advertising: including mandatory warnings and restrictions on misleading or aggressive marketing.
- Stronger consumer protection: including stricter creditworthiness assessment requirements, refining regulations on advisory services and a ban on bundled sales.
Polish implementation of CDD2
The Polish implementation of CCD2 is currently at the public consultation stage, with comments being accepted until early August 2025. This is a key opportunity for all market participants to submit feedback and propose amendments to the draft legislation.
The initial proposal, prepared by the Polish Office of Competition and Consumer Protection, largely reflects the content and objectives of CCD2, however, certain elements go beyond the EU baseline (a practice known as gold-plating) or adopt stricter measures within the EU’s permissible scope, and may warrant particular attention.
These include, for example:
- Consumer credit regime now applicable to low-value or short-term credit: CDD2 allows to exempt certain credit products (e.g., below EUR 200, short-term, free of charge) from some obligations. The Polish draft does not introduce any such exemptions.
- CPI products offering: the Polish draft stipulates strict requirements for offering CPI products to consumers. The creditor may demand conclusion of such agreement only in specific circumstances and must accept a CPI product organized and presented by the consumer to creditor itself.
- No exclusion of deferred debit cards: CDD2 permits to exclude deferred debit cards from its scope, provided certain conditions are met. The Polish draft does not make use of this derogation, again opting for broader application than strictly required.
- Ban on certain advertising tactics: CDD2 allows to optionally prohibit additional certain types of advertising content that may mislead or pressure consumers, for example ads emphasizing the ease or speed of obtaining credit. The Polish draft makes full use of this option.
- Stricter wording on creditworthiness outcome: The Polish draft requires that a credit may be granted only if the assessment demonstrates that the consumer is able to repay the credit, which may require a higher degree of certainty in creditworthiness assessments. At the same time CCD2 allows granting credit where the consumer is likely to meet their obligations.
- Mandatory registration for additional credit services: The Polish draft introduces a registration obligation for entities engaging in so-called ‘additional credit activities’, including sellers or service providers who intend to offer credit in the form of deferred payment (e.g. BNPL) for the purchase of goods and services offered by them.
- Training requirements: The Polish draft imposes an obligation on creditors and intermediaries to ensure that their staff undergo consumer credit-related training before commencing their activities and at least once every 3 years. This obligation is more specific and demanding in comparison to the CCD2 general knowledge and competence requirement.
Timeline and support
Member States are required to transpose the new rules by 20 November 2025, with full application starting from 20 November 2026. Given the scale of changes, credit providers operating in Poland, and across the EU, should begin preparing now. Early preparation will support a smooth transition and help ensure future regulatory compliance.
Our legal team is closely monitoring the Polish implementation process and offers tailored support for addressing your organization’s readiness and navigating the upcoming changes.
Contact us for more information.
