The Danish Financial Supervisory Authority and the Danish Consumer Ombudsman published new joint guidance on creditworthiness assessments, setting out high-level principles and clarifying that lenders may tailor their assessment of a consumer’s finances to the specific loan within the consumer-protection purpose of the rules. The guidance reiterates the requirement for a concrete, individual assessment, but specifies that lenders have discretion over which information to collect and document. It allows the assessment process to be adapted to factors such as loan size and the consumer’s financial situation, permits the use of estimates where they provide a fair picture of the consumer’s finances or to validate consumer-provided information, and allows sufficiently certain future income and relevant local knowledge to be taken into account. The new guidance replaces the authorities’ joint guidance from 2021.
Danish Finanstilsynet 2025-11-25
Danish Financial Supervisory Authority and the Danish Consumer Ombudsman issue updated guidance on flexible consumer creditworthiness assessments
The Danish Financial Supervisory Authority and the Danish Consumer Ombudsman issued new joint guidance on creditworthiness assessments, emphasizing high-level principles and allowing lenders discretion in tailoring assessments to specific loans. The guidance permits adaptation based on loan size, consumer financial situation, use of estimates, and consideration of future income and local knowledge. This replaces the previous guidance from 2021.