Germany finalises its CCD 2023 implementation: the new regime for consumer credit at a glance

After a period of legislative debate, clarity has finally arrived for the future of German (non‑mortgage) consumer credit. The draft act implementing the EU’s revised Consumer Credit Directive 2023/2225/EU (CCD 2023) – including a number of adjustments and deviations from the initial government draft agreed during the parliamentary deliberations – passed the German Bundestag on 17 April. It will be up for discussion on 8 May in the Bundesrat, the chamber of the German Länder, which is unlikely to dissent. As the adjusted draft proceeds through the remaining stages of the legislative procedure, it provides a concrete legal framework for the years ahead.

While the new rules are only expected to be formally adopted by mid‑May – around half a year after the actual transposition deadline – the original application date of 20 November 2026 remains unchanged. This briefing unpacks the essential changes to support your preparation and further refinements in the run‑up to that date.