The Dutch Authority for the Financial Markets has published an exploratory paper on how digitalisation could reshape the credit-lending sector by 2035, focusing on mortgage and consumer credit. The paper sets out expected developments in data-driven, increasingly automated credit processes and highlights the opportunities for consumers alongside emerging risks for consumer protection, conduct supervision and privacy. The AFM anticipates a “one click away” credit market in which lenders further digitise and personalise the customer journey, collect more data and use more advanced analytics, increasingly supported by artificial intelligence across the credit value chain. EU open finance legislative initiatives could expand lenders’ access to third-party data sources, enabling more granular creditworthiness assessments and more tailored offers, while AI may also take a larger role in customer interaction, including through online mortgage portals with advisers on standby. While the AFM notes potential consumer benefits such as lower barriers, greater convenience, earlier identification of payment problems and accessible payment solutions, it also points to risks including debt becoming more normalised, customer exclusion driven by fine-grained analytics, and privacy issues. Key questions highlighted include the impact of instant credit, how to prevent exclusion without undermining access, the risk that personalisation leads to unequal treatment, supervision of a more complex and interconnected credit ecosystem, and how technological trends fit with existing conduct and privacy rules; the AFM calls on firms and other stakeholders to engage in further dialogue on these issues.

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