Dutch Authority for the Financial Markets opens early licensing applications for revised consumer credit rules covering buy now pay later

The Dutch Authority for the Financial Markets has opened the way for firms to apply now for licenses under the revised Consumer Credit Directive ahead of the Dutch implementing law, which is due to take effect on 20 November 2026. The new regime will impose new and amended obligations on consumer credit providers and extend conduct supervision under the Financial Supervision Act to credit products that were previously outside scope, including deferred payment services such as buy now, pay later. Firms must assess whether the new rules create a licensing or registration obligation. The AFM identified providers of deferred payment services, deferred debit cards, and hire or lease agreements with a purchase option as products that may fall under the licensing requirement in Article 2:60 of the Financial Supervision Act. Large intermediaries in short-term buy now, pay later credit may fall under the registration requirement in Article 2:81, while intermediaries in newly in-scope credit products that do not qualify for an exception, exemption or registration may need a license under Article 2:80. Applications can be submitted before the implementing law is finalized, but applicants bear the cost and risk if the final legal framework differs from current assumptions, and any license will not take effect before the implementing law enters into force. The AFM also highlighted three continuing areas of obligation under the revised framework. Responsible lending will remain an open norm, with the AFM pointing to a proportional approach where each credit drawdown has a repayment period of no more than three months, and encouraging sectorwide agreement on acceptance policies. The implementing law will also require age verification using a reliable source, such as iDIN or itsme, and introduce standards for early identification of consumers in financial difficulty and referral to debt advice services. The AFM said it will update its guidance on consumers and debt collection to reflect those new standards, and that further information on registration of large deferred-payment intermediaries, including conditions and fees, will follow later this year.