DO YOU OFFER OR MEDIATE CREDIT TO CONSUMERS? YOUR COMPANY MAY SOON BE SUBJECT TO NEW SUPERVISION

On 20 November 2026, new rules in Swedish Consumer Credit Act (the “Credit Act”) will come into effect.

For the first time, a new group of companies will come under official oversight: Businesses that offer credit as a subsidiary (side) service and those that help arrange (mediate) credit for customers.

Now is the time to prepare!

But what do these changes mean in practice, and which companies need to take action?

WHO IS COVERED BY THE NEW RULES?

These rules apply to companies that offer or help arrange credit, even if lending is not their main business. Common examples include:

1. Shops that let customers pay in instalments

2. Online stores that offer “buy now, pay later” options

3. Retailers that partner with banks or finance companies to offer credit and receive a fee for doing so (such as electronics stores and car dealerships)

If your company lets consumers pay on credit – even as a small part of your business – you may be affected by these new rules.

However, for companies that help arrange credit (rather than provide it directly), there is one key condition: The company must receive payment from the lender for your role in setting up the credit.

WHO WILL OVERSEE YOUR COMPANY – THE FINANCIAL SUPERVISORY AUTHORITY OR THE CONSUMER AGENCY?

Which government agency will regulate your company depends on its size and what it does.

For companies that help arrange credit, there are certain thresholds which determine if you will be subject to a license. Larger companies – those with more than 250 employees and either annual sales over EUR 50 million or total assets over EUR 43 million – will be regulated by the Swedish Financial Supervisory Authority (Finansinspektionen) and must apply for a licence.

Smaller companies that help arrange credit will be regulated by the Swedish Consumer Agency instead and do not need to apply for a licence. They will be under the Agency’s supervision by default.

For companies that provide credit directly, the rules are more complicated. Several factors come into play, including whether you charge interest or fees, the size of your company, how long customers have to pay, and whether you sell online or in physical stores.

WHAT DO YOU NEED TO DO?

If your company needs a licence from the Financial Supervisory Authority, the deadline depends on when you started or will start offering consumer credit:

1. Already in business? If you are offering credit on 20 November 2026, you must submit your licence application by 20 November 2027. You can continue operating while your application is being processed.

2. Starting after 20 November 2026? You must have your licence approved before you can begin offering credit.

STAFF TRAINING REQUIREMENTS

The new rules require that staff who handle credit applications or help customers arrange financing have proper training. This includes understanding consumer rights – a requirement that applies regardless of which agency regulates your company.

TOUGHER RULES FOR CREDIT CHECKS

Alongside these changes, a new Consumer Credit Act is introduced. This act sets tougher standards for checking whether customers can afford the credit they are applying for. Companies will need to have better processes and keep more detailed records.

BACKGROUND: NEW EU RULES ON CONSUMER CREDIT

These changes stem from a new EU directive on consumer credit (CCD2) that took effect on 20 November 2025. Sweden is now updating its regulations to match. The existing act on mortgage credit is being expanded to also cover consumer credit, which is why a new, broader “Consumer Credit Act” is being created. The aim is to give consumers better protection and make the rules consistent across the EU.

TIME TO TAKE ACTION!

If your company offers or helps arrange credit for consumers – whether through invoices, instalment plans, or any other method – it is time to:

1. Check whether the new rules apply to your business

2. Find out which government agency will regulate you

3. Determine if you need a licence and start the application process if so

4. Assess your staff’s knowledge and identify any training needs

5. Review how you check customers’ ability to pay against the new standards

The rules are complex and the boundaries are not always clear-cut. Many companies that have never seen themselves as part of the financial industry will now face regulation. Start preparing now – the deadlines may come faster than you expect.

Have questions about how these new rules might affect your business? Do you need assistance with applying for a license to the Swedish Financial Supervisory Authority?

Please get in touch at ohan.ragnar@synch.law and we will be happy to help you understand what you need to do.

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