05/09/2026

CCD II for Telecoms: Compliance Guide by 20 Nov 2026

CCD II for Telecoms: New Creditworthiness Rules and How to Prepare

The European Union adopted the Consumer Credit Directive II (CCD II, Directive (EU) 2023/2225) at the end of 2023. It sets the conditions under which consumers may be offered financing, including buying a phone or other device in instalments. The directive becomes binding on 20 November 2026. In Croatia it has been transposed by the recently adopted Consumer Credit Act (Official Gazette 86/26), which enters into force on the same date.

For telecom operators, CCD II means five major changes: strong identity verification, a mandatory creditworthiness assessment, qualified or advanced electronic signatures, full audit trails and a consistent process across every EU market. Below we explain what changes, why it applies to telecoms, and which digital solutions can help you comply.

What Is CCD II and Why Does It Apply to Telecoms?

CCD II replaces the 2008 Consumer Credit Directive and extends regulation to forms of financing that were previously exempt, such as short-term and interest-free credit and micro-loans under €200. Instalment deals for devices were often exempt precisely because they were short-term and interest-free. CCD II closes that gap, so models such as buying a phone in instalments or deferred payment for equipment (including buy now, pay later schemes) now fall under the full creditworthiness assessment and consumer protection rules.

This means telecoms, although they are not banks, act as lenders in practice whenever they offer devices with instalment payment. They must therefore meet the same requirements as traditional creditors.

CCD II Compliance Deadlines

Date Milestone
19 November 2023 CCD II (Directive (EU) 2023/2225) enters into force at EU level.
20 November 2025 Deadline for Member States to adopt national implementing legislation.
7 August 2026 Croatia publishes the Consumer Credit Act (Official Gazette 86/26), transposing CCD II.
20 November 2026 The Act enters into force and the rules become mandatory for all lenders, including telecoms.

 

Five Key CCD II Changes for Telecom Operators

The directive and the new Croatian Act directly change how devices are sold and services are contracted:

  • Strong identity verification: a quick look at an ID card is no longer enough. Expect electronic identification or document checks backed by biometric data.
  • Mandatory creditworthiness assessment for all credit: this includes credit under €200, to ensure safe repayment and reduce the risk of consumer over-indebtedness.
  • Qualified or advanced electronic signatures: a simple “click to sign” will no longer be sufficient for contracts covered by the new law.
  • Audit trails for every process: each step of identity verification, creditworthiness assessment and signing must be recorded and provable during supervision.
  • Consistent coverage across the EU: operators active in several countries must deliver an equally compliant process in each one, regardless of local differences in implementation.

What Happens If a Telecom Fails to Comply With CCD II?

CCD II requires every Member State to set penalties for non-compliance that are effective, proportionate and dissuasive. The exact amounts and supervisory mechanisms are defined by national law. In Croatia this is governed by the new Consumer Credit Act, so the specific penalties and the competent supervisory authority for telecoms as lenders should be checked directly in the legal text before you communicate with customers.

Digital Solutions for CCD II-Compliant Telecom Operations

A smooth customer experience and fast service remain the main competitive advantages. At the same time, data security matters more than ever, because the directive requires a wider set of customer data to be collected. To help telecoms align quickly and without interrupting business, there are advanced solutions for each of the requirements above:

  • SelfID (instant activation): with biometric face verification, customers can activate a service in seconds, with no store visit and no waiting for delivery. Automated liveness detection confirms that a real person is behind the screen.
  • NFCID (remote security): for subscriptions with high-value devices, NFC reading of the ID card chip confirms the document is authentic and protects the operator from fraudulent contracts.
  • KYCID and KYBID (fraud prevention): alongside sanctions and PEP screening, these methods enable in-depth risk analysis and prevent subscription fraud, especially for business customers ordering equipment in larger volumes.
  • WalletID (ready for the EUDI Wallet): the upcoming European Digital Identity Wallet (EUDI Wallet) will transform identity verification for telecoms, removing manual document scanning and lowering customer support costs.
  • eSIG: qualified and advanced electronic signatures for contracts and other documents, in store or remotely.

Read more: [EUDI Wallet: The Digital Identity Revolution – Are You Ready for 2027?]

Your Roadmap to CCD II Compliance

  1. Identify which of your products (device instalment sales, deferred payment) fall under the new law.
  2. Map your current sales process and find the steps where strong identity verification or a creditworthiness assessment is missing.
  3. Choose digital identification, document verification and qualified signing solutions that integrate with your existing systems.
  4. Make sure every process records the audit trail needed to prove compliance.
  5. Pilot the new process in one sales channel before a full rollout.
  6. Train sales staff and customer support on the new steps before 20 November 2026.

Turn CCD II Compliance Into a Competitive Advantage

For telecoms, CCD II is not just a compliance cost. It is a chance to speed up service activation and strengthen customer trust. Contact us to see the quality and security of these solutions for yourself. [Contact our experts]

Author: Sara Sever