At its 14 April 2026 meeting, Moldova's National Commission for Financial Markets (CNPF) adopted a package of decisions spanning market regulation and consumer protection, including changes to how it levies supervisory fees and enforcement steps following a review of consumer credit documentation used by BC “OTP Bank” SA. The fees and payments instruction was amended to align it with Law No. 189/2025 and related legal adjustments, updating the fee calculation mechanism, revising how payments owed by insurance intermediaries are determined, extending the instruction to savings and loan associations, and adjusting annexes to support uniform application. Separately, after examining a petition, CNPF identified breaches of Law No. 202/2013 on consumer credit contracts in OTP Bank’s credit and suretyship agreements, including missing standard pre-contractual information, non-compliant early repayment terms with unjustified prior-notice requirements and improper charges, abusive clauses limiting consumer rights, unclear drafting on penalties and the definition of a “banking day”, and overly restrictive clauses affecting guarantors. The amended fees instruction takes effect on adoption and is to be published in the Official Gazette of the Republic of Moldova. CNPF will bring a court action seeking a finding that the identified abusive clauses are null.
National Commission for Financial Markets 2026-04-17
Moldova's National Commission for Financial Markets amends its fees instruction and will challenge OTP Bank consumer credit clauses in court
Moldova’s National Commission for Financial Markets amended its fees and payments instruction to align with Law No. 189/2025, updating supervisory fee calculations, revising payments by insurance intermediaries, extending the framework to savings and loan associations, and adjusting annexes. After reviewing BC “OTP Bank” SA’s consumer credit and suretyship documentation, the authority found breaches of Law No. 202/2013, including missing pre-contractual information, non-compliant early repayment terms, abusive clauses and unclear penalty provisions, and will seek a court ruling declaring the abusive clauses null.