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Dutch consumer credit bill passes the Tweede Kamer, but 20 November looks out of reach

The Tweede Kamer adopted bill 36924 on 6 October 2026. The Eerste Kamer has not scheduled a vote, and the Act takes effect on a date set by royal decree, so a start on 20 November 2026 is unlikely. Credit providers and BNPL firms should plan on a later Dutch date.

3 min read

Will the Dutch consumer credit rules apply from 20 November 2026?

Probably not. The Tweede Kamer adopted bill 36924, the Implementatiewet herziene richtlijn consumentenkrediet, on 6 October 2026 by a show of hands, with only FVD voting against. The Eerste Kamer has set 27 October 2026 as the deadline for its committee's written input and has not scheduled a vote. The Act takes effect on a date set by royal decree.

Directive (EU) 2023/2225 says the national rules apply from 20 November 2026. The Netherlands already missed the transposition deadline of 20 November 2025. In a note of 12 October 2026, Loyens & Loeff expects publication of the Act no earlier than 17 December 2026 and concludes that the 20 November date will not be met.

That is a law firm's reading, not a government announcement.

How the bill got here

Each label gives the date as the source states it and who set it.

2025

  1. 20 November 2025 · Set by law

    Transposition deadline for Directive (EU) 2023/2225 passes without a Dutch Act

2026

  1. 18 June 2026 · Set by the AFM

    AFM opens licence applications, at the applicant's own cost and risk

  2. 28 September 2026 · Set by the Tweede Kamer

    Legislative committee meeting on the bill; no plenary debate follows

  3. 6 October 2026 · Set by the Tweede Kamer

    Bill 36924 adopted, with motions on BNPL warnings and AFM guidance

  4. 27 October 2026 · Set by the Eerste Kamer

    Deadline for the Eerste Kamer committee's written input

  5. 20 November 2026 · Set by law

    Date the Directive sets for applying the national rules

What it means for credit providers and BNPL firms

Nothing changes in Dutch law until the royal decree sets the date. The current rules keep applying to your products in the meantime.

The licence is the long lead item. A buy now, pay later provider that grants credit needs an AFM licence under Article 2:60 of the Wft, and a licence cannot take effect before the Act does. The AFM has accepted applications since June 2026. Large companies that act as credit intermediary on the side register under Article 2:81 Wft instead. For credit cards with deferred debit, the bill adds six months after the Act takes effect.

Two parts of the bill touch the checkout directly: deferred payment is closed to minors, and the draft implementing decree requires a BKR check for every credit, however small.

The motions to watch

On 6 October the Tweede Kamer also adopted five motions. They ask the government for AFM guidance on which everyday payment and invoicing methods count as credit, a mandatory warning sentence at BNPL checkouts, fees without a profit margin, monitoring of the new rules, and age as an explicit risk factor in the creditworthiness assessment.

Motions are requests to the government. None of them is law yet.

Authorities

  • Autoriteit Financiële Markten (AFM)

    The AFM is the Dutch conduct supervisor. It supervises how financial firms behave towards their customers and towards the market: investment firms, asset managers, intermediaries, crypto-asset service providers, audit firms, trading venues and listed issuers. Whether those firms are financially sound is DNB's question, not the AFM's.

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