AFM Opens Early CCDII Licence Applications: What Firms Need to Do Before November 2026
The Dutch Authority for the Financial Markets (AFM) announced on 18 June 2026 that it is already accepting licence applications under the revised Consumer Credit Directive (CCDII), which enters into force in the Netherlands on 20 November 2026. Firms that will need a new licence or registration under the expanded scope of the Dutch Financial Supervision Act (Wet op het financieel toezicht, Wft) are being urged to apply now rather than wait for the implementing legislation to be finalised. For accounting firms advising clients in the Dutch consumer credit space, including buy-now-pay-later (BNPL) operators and lease providers, this is an immediate compliance trigger.
What the CCDII Changes in the Netherlands
The CCDII replaces the original Consumer Credit Directive and broadens the range of credit products subject to regulatory oversight. The Dutch implementing law is still being prepared, but its scope is clear enough that the AFM has decided to begin processing applications in advance.
Newly captured product categories
Several credit types that were previously exempt from Wft supervision will fall under it from November 2026. These include:
- Deferred payment services, most notably buy-now-pay-later arrangements
- Cards with deferred debit functionality
- Hire or lease agreements that include a purchase option
Providers of these products must assess whether they will be subject to the licence requirement under Article 2:60 Wft. Large intermediaries in short-term BNPL credit must also assess whether they fall under the registration obligation in Article 2:81 Wft. Intermediaries in any newly supervised credit form that do not qualify for an exemption or a lighter registration route will face a full licence requirement under Article 2:80 Wft.
Why the AFM Is Acting Before the Law Is Final
The AFM stated that it consulted a number of market participants and decided to open for applications early precisely to help ensure timely assessment before the 20 November 2026 deadline. Processing a licence application takes time; firms that wait until the implementing legislation is published risk not receiving their decision before the directive becomes operative.
The risk firms are accepting by applying early
The regulator is explicit that early applications are submitted at the applicant's own cost and risk. If the final implementing law differs from current assumptions, the application cannot automatically be adjusted free of charge. The licence itself will not take effect until the Dutch implementing law formally enters into force. Firms need to factor this into their project plans: apply early to get in the queue, but stay alert to any legislative changes that may affect the scope of what they are applying for.
Three New Substantive Obligations to Plan For
Beyond the licensing question, the CCDII introduces or modifies a set of operational requirements that will affect how credit providers run their businesses. Accounting advisers need to understand these because they directly affect client provisioning, systems, and staff training spend.
Responsible lending under an open norm
The CCDII retains an open-norm approach to responsible lending, meaning providers must interpret and apply the standard proportionately. The AFM has indicated that a proportionate application is appropriate where a repayment obligation per credit draw does not extend beyond three months. The AFM is also encouraging the sector to agree on shared acceptance criteria to prevent a competitive race to the bottom on credit standards.
Age verification requirements
The implementing law will require credit providers to verify consumer age using a reliable source. The AFM's guidance references iDIN and itsme as examples of suitable verification methods, though the choice of method remains with the individual provider. Firms offering digital credit channels will need to build or integrate age verification into their onboarding flows before November 2026.
Early intervention and debt referral
Providers will be required to identify consumers showing early signs of financial difficulty and refer them to appropriate debt counselling services. The AFM has confirmed it will update its Leidraad Consumenten en Incassotrajecten (Guideline on Consumers and Collection Processes) to incorporate these new standards. Firms should watch for that updated guidance and review their arrears-management procedures accordingly.
Practical Steps for Firms and Their Advisers
The CCDII's expanded scope, combined with the AFM's decision to open applications early, creates a short planning window. Firms advising Dutch clients in the consumer credit sector should be taking the following steps now.
Scope assessment first
Before any application is filed, each entity in a client's group structure needs a clear determination of whether it will be a newly captured provider or intermediary. The licence and registration routes are different, the costs differ, and the ongoing obligations are not identical. Getting this wrong at the outset wastes application fees and delays the process.
Start the application process
The AFM has made its application pages available. Firms that have completed their scope assessment and concluded that a licence or registration is needed should begin the process. Given the acknowledged risk that the regulator's assessment cannot yet be fully benchmarked against the final law, document your legal reasoning carefully so it can be updated if the implementing legislation introduces surprises.
Monitor the implementing legislation
The Dutch implementing law has not yet been finalised. Firms should track its progress and be prepared to supplement or amend applications once the text is available. The AFM has said further information on the BNPL intermediary registration process, including conditions and fees, will follow later in 2026.
This regulatory expansion reflects a broader European trend of bringing previously unregulated credit products within formal supervisory perimeters. Accounting and compliance professionals already familiar with AFM's approach to digital financial services, including the requirements the regulator set out for online interfaces under the Distance Marketing Financial Services Directive as covered in AFM's earlier Distance Marketing Financial Services Directive requirements for crypto service providers, will recognise the pattern: the regulator acts early, expects firms to self-assess, and applies conduct supervision from day one. The same mindset applies here.
For firms operating across multiple EU jurisdictions, the CCDII is a harmonised directive, which means similar licensing obligations will be introduced in other member states on the same November 2026 timetable. The Dutch process is simply further advanced because the AFM has decided to open applications before the implementing law is enacted. Teams already navigating the MiCA transitional period and mandatory CASP authorisation across the EU will find the project management disciplines directly transferable.
Frequently Asked Questions
Can a firm apply for a CCDII licence before the Dutch implementing law is final?
Yes. The AFM confirmed on 18 June 2026 that it is accepting applications now, ahead of legislative finalisation, to help ensure timely processing before the 20 November 2026 implementation date. Applications are submitted at the firm's own cost and risk.
Which firms need to apply for a new licence under CCDII in the Netherlands?
Providers of deferred payment services (including BNPL), deferred debit card products, and hire/lease agreements with a purchase option must assess whether they fall under Article 2:60 Wft. Intermediaries in newly supervised credit forms that do not qualify for an exemption will need a licence under Article 2:80 Wft. Large BNPL intermediaries should assess the registration route under Article 2:81 Wft.
When does the CCDII licence actually take effect?
Even if the AFM processes an application now, the resulting licence cannot legally take effect until the Dutch implementing law enters into force on 20 November 2026.
What are the main new operational obligations under CCDII?
Three key areas: responsible lending under a proportionate open norm, mandatory age verification using a reliable source such as iDIN or itsme, and early identification of consumers in financial difficulty with referral to debt counselling services.
Where can firms find the AFM's application procedure and fee information?
The AFM has published application pages for credit providers and intermediaries on its website. Further information on the BNPL intermediary registration process, including conditions and costs, is expected later in 2026. Firms should subscribe to the AFM newsletter to receive updates as the implementing legislation progresses.
Source: AFM