The Danish Financial Supervisory Authority has published questions and answers clarifying when benefits other than direct payments bring firms within the credit intermediary registration requirement. Under the previously announced requirement, firms that help consumers find or obtain credit in return for remuneration or another agreed financial consideration from a lender must be registered from Nov. 20, 2026. Remuneration can include reduced fees, access to a customer base, marketing or exposure where the benefit is linked to credit intermediation. A firm may receive such consideration even if it pays the lender, for example for access to its financing solution. A general expectation of increased sales is not sufficient on its own. Each assessment must consider the cooperation agreement, the customer journey and the economic relationship between the firm’s activities and the benefits it receives.
Danish Financial Supervisory Authority clarifies how indirect remuneration affects credit intermediary registration
The Danish Financial Supervisory Authority has clarified that indirect financial benefits can bring firms helping consumers obtain credit within the registration requirement applying from Nov. 20, 2026. Benefits linked to intermediation may count even where the firm pays the lender. Expected sales growth alone is insufficient, with each assessment depending on the agreement, customer journey and economic relationship.