Directive (EU) 2023/2225, the recast Consumer Credit Directive (CCD2), applies from 20 November 2026, the same day in every member state. What each state's law says by then is a separate question.
CCD1 exempted short-term, low-value, no-interest credit, and buy-now-pay-later grew inside that exemption. CCD2 closes it [Directive (EU) 2023/2225, Recitals 15–16 and Art. 2]. Pay-in-3 and pay-in-4 BNPL, longer instalment credit, revolving credit and credit cards with deferral, overdraft, and consumer leasing with a purchase option all move into scope. Pure operational leasing, with no purchase option, stays out [Art. 2(2)(d)]. A platform built to reason about one of these products, BNPL for example, does not cover the ground the directive now covers.
The application date is 20 November 2026, set by Article 48 of the directive. That date does not move and is the same in every member state. The national law each state passes to implement the directive is a separate, ongoing process, on its own timeline per market. A cross-border business faces one go-live date sitting on top of rulebooks that are still being finalised under it, market by market.
The directive is written for a human consumer and does not mention an agent acting on one. Article 5 requires the consumer to receive the pre-contractual information; Article 10 requires it "in good time before the consumer is bound", language that assumes a human is reading it. The workable shape is agent-prepared, human-confirmed: an agent can assemble a credit transaction, but a human still has to see and confirm it before it is entered into. That is the same question verifying an agent's authority to transact already answers for agentic checkout in general. Consumer credit is the case where confirming a human is not optional.
This page describes the regime as published. It is not legal advice; talk to your own counsel about how CCD2 applies to your product.