Cat-16 · T482 · EU Consumer Credit · CCD2 Art. 18

CCD2 Creditworthiness Assessment Builder

Build an Article 18 creditworthiness assessment framework under CCD2 (Directive (EU) 2023/2225). Validates forward-looking, verified-financial-data requirements. Flags reliance on behavioural-only signals as non-compliant. Cross-links to EU AI Act cluster for automated-decision human-review obligations.

EU Regime (CCD2 Art. 18): Distinct from the UK FCA DPC creditworthiness framework (T330). Art. 18 CCD2 requires assessment based on verified financial data (income, expenses, debts): behavioural signals alone are insufficient.

CCD2 · Art. 18 Verified data required Applies 20 Nov 2026 Zero PII · Client-side

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Data Sources: Art. 18(2) Verified Financial Data

CCD2 Art. 18 requires creditworthiness assessment based on verified financial data proportionate to the amount. Check all data sources available and used:

Income verified (payslips, bank statements, tax returns)

Essential household expenses verified

Existing debt/commitments checked

Credit database / credit bureau consulted (Art. 18(5))

Open banking / account data used

Consumer self-declared financial information

Assessment Method: Art. 18 Compliance Flags

Assessment relies exclusively on automated/behavioural scoring (non-compliant under Art. 18)

Human review path available on automated decisions

Assessment is forward-looking (future repayment capacity)

Reassessment triggered on significant credit increase

Grant/decline outcome documented per Art. 18(7)

Consumer informed of decline and reason (Art. 18(9): verify)