Pay-later flows, subscriptions, payment plans, charging cards, telecom contracts and deferred collections may fall under CCD2 impact. From 20 November 2026, organizations must be able to show that credit-related processes are responsible, controllable and audit-ready.
Built for European compliance, Open Banking and audit-ready decisioning.
CCD2 does not only affect banks and Buy Now Pay Later providers. Many organizations unknowingly offer forms of credit or deferred payment.
Not sure whether your organization is affected? Use the CCD2 Impact Checker for an initial indication.
Answer a few questions and instantly get an indication of whether CCD2 may be relevant for your organization.
Based on your answers, CCD2 appears less directly applicable, but regulation and interpretation can differ by sector.
CCD2 is designed to better protect consumers in credit, deferred payment and financial obligation scenarios. For organizations, this means that onboarding, affordability, transparency, monitoring and auditability become far more important.
Lightweight checks, fragmented processes and limited auditability.
CCD2 expands the scope and raises expectations around decisioning.
Affordability checks, documented decisions, transparency, monitoring and compliant recovery.
Organizations need to better demonstrate that consumers can afford financial obligations before credit or deferred payment is offered.
Supervision, sanctions and mandatory remediation.
Manual processes, fragmented checks and inconsistent decision-making.
Slower onboarding, higher drop-off and missed revenue due to friction.
Loss of trust from customers, partners and regulators.
Often incorrect. Subscriptions, pay-later flows and payment plans may still fall under CCD2.
Authorizations, affordability checks and audit trails require months of preparation.
CCD2 affects revenue, onboarding, customer acceptance, payments and collections.
CCD2-ready customer onboarding.
Payment behavior as a real-time signal.
Responsible recovery and auditable customer care.
Many organizations are here without realizing it. Decisions are made manually, payment data is spread across systems and evidence is often missing. Credit risks are assessed reactively instead of monitored structurally.
CCD2 requires demonstrable and reproducible decision-making. Without structure, compliance becomes costly, error-prone and hard to scale.
Organizations that implement CCD2 intelligently do not only build a compliant process, but improve acceptance, cashflow and retention.
Compliance does not have to slow growth.
Traditional credit data often looks backward. Open Banking makes it possible to include current affordability, income, expenses and behavioral patterns in onboarding and monitoring.
Always with consent, data minimization and GDPR-by-design.
Post-paid contracts, devices and payment plans.
Charging cards, leasing, shared mobility and mobility credits.
Subscriptions with deferred payment or recurring collection.
Payment arrears, repayment plans and customer care.
Long-term obligations with onboarding and payment risk.
Credit, BNPL and consumer payment solutions.
Rebillix is built for European revenue teams that want to use AI without losing control over data, compliance and customer care.
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Take the CCD2 Impact Check and discover which parts of your onboarding, payment and recovery process may be affected.