Advertising of consumer credit under the UKK2 Draft

We advised lender in:

Assessment of proposed advertising messages in light of the proposed consumer credit bill

In February 2026, the Office of Competition and Consumer Protection published a new version of the draft Consumer Credit Act—the draft dated February 25, 2026 (UKK2 Draft), which will implement Directive 2023/2225 of October 18, 2023, on consumer credit agreements and repealing Directive 2008/48/EC (CCD2).

Draft UKK2 provides, among other things, that:

1. advertisements for consumer credit must include a clear and explicit warning indicating that consumer credit involves certain costs, using the phrase “Warning! Borrowing money costs money” or another equivalent phrase.
2. that all advertising information and marketing communications regarding consumer credit:
   1. be unambiguous, reliable, and not misleading to the consumer;
   2. not contain wording that could create false expectations in the consumer regarding the availability and costs of the consumer credit borne by the consumer or the total amount to be paid.

In addition, the UKK2 Draft provides a list of prohibited advertisements. As a result, consumer credit advertising is to be prohibited if it:

1. suggests that consumer credit will improve the consumer’s financial situation;
2. indicates that outstanding loans, including those recorded in databases, have no impact or only a minor impact on the assessment of a consumer credit application;
3. suggests that consumer credit leads to an increase in financial resources, constitutes a form of savings, or can raise the consumer’s standard of living;
4. emphasizes the ease or speed of obtaining a consumer loan;
5. indicates that a discount is contingent upon taking out a consumer loan;
6. offers a deferral of consumer loan installment payments for periods longer than three months.

DLK’s advisory included:

• a legal analysis of proposed consumer loan advertisements and marketing content in light of the UKK2 Draft
• the preparation of a legal opinion, including practical recommendations regarding the desired structure of the proposed advertisements and marketing content in light of the UKK2 Draft