From 20 November 2026, consumer credit includes products you may not think of as loans

After fifteen years, Slovakia’s consumer credit act is being replaced by a new one. Act No. 312/2025 Z. z. on consumer credit and other consumer loans takes effect in its main part on 20 November 2026. It implements Directive 2023/2225, which replaced the 2008 Consumer Credit Directive.

Banks and non-bank lenders expected the change. More interesting is who else it affects.

Expanded scope is the main development

The previous regime excluded many products considered minor or harmless. The new rules largely remove those exemptions, bringing in particularly:

• Buy-now-pay-later arrangements provided by a third party, such as payment options integrated into online checkouts.
• Small loans previously below the scope threshold.
• Interest-free and fee-free loans, previously excluded because they cost consumers nothing.
• Short-term loans repayable within a few months.
• Leasing agreements with a right or obligation to acquire ownership.

The upper threshold also rises from EUR 75,000 to EUR 100,000 (§ 1(3)(c)), but the Act provides exceptions. Under § 1(2), this threshold does not apply to newlywed loans, specified building loans and unsecured loans for renovating residential property. Conversely, certain obligations do not apply to loans below EUR 200, interest-free loans and loans repayable within three months with insignificant charges (§ 1(6)). The precise regime must therefore be determined by reference to the product, not merely its amount.

Some room remains. The Act does not cover deferred payment provided by the seller itself without third-party credit, free of interest and of any charges other than late-payment charges, if paid within 50 days of delivery. For a large online seller that is not a small or medium-sized enterprise, the exemption helps only if the customer pays the full amount within 14 days (§ 1(3)(h)). But the exemption is much narrower than before, and its conditions must be tested against the actual model, not estimated.

Why online stores should care

Imagine a store offering later payment or instalments at checkout through a partner. Previously viewed as a payment method, the decisive questions now are who actually lends the money, for how long and at what cost to the consumer. The answers determine whether consumer credit duties apply.

Those duties are substantial: prescribed pre-contractual information, advertising rules, assessment of repayment capacity and rules governing default. A business that saw itself only as a seller may enter a role for which it lacks both processes and documents.

The first step is factual: identify precisely what your model does. Who is the creditor, when is payment due, is it truly free and what do your terms and conditions say?

Further changes introduced by the directive

The European framework changes lenders’ everyday practice in several ways.

Advertising warning. Credit advertising must contain a clear and prominent warning, “Attention! Borrowing money costs money.”, or similar wording. If it states an interest rate or any figure relating to cost, it must add, by way of a representative example, standard information such as APR, total credit amount, duration and total payable (§ 5(2) and (3)).

Pre-contractual information on one page. Information is provided using the Standard European Consumer Credit Information form, with the key details in its first part clearly set out on one page, or two at most (§ 8(5)). It must arrive in good time before conclusion, not at signing.

Clear limits on creditworthiness assessment. Assessment uses income, expenditure, existing commitments and living costs. Neither the lender nor a financial agent may process special categories of personal data, such as health data, or personal data from social networks (§ 18(4)).

Rules for automated decisions. Where assessment is automated, consumers may request that the decision be verified by non-automated means and are entitled to an understandable explanation of the assessment, to express their own view and to a review of the outcome (§ 17). Scoring models should account for these rights from design.

Measures before recovery. Lenders must have policies and procedures to adjust repayment terms appropriately for the consumer in suitable cases before enforcement proceedings begin, for example by extending the agreement, changing its type, deferring instalments, reducing interest, or partially forgiving and consolidating the debt (§ 47(1)).

Authorisation will reach previously unlicensed businesses

The Act uses several authorisation categories according to scale and operating model, including entities providing interest-free credit as an ancillary activity.

The practical consequence is clear: some businesses requiring no authorisation today will need one. Anyone who lawfully provided such credit without authorisation before 20 November 2026 may continue until 20 March 2027 at the latest; to continue beyond that, they must apply for authorisation (§ 58(6) and (7)). By contrast, a small or medium-sized enterprise offering deferred payment for its own goods or services as an ancillary activity, free of interest and of charges other than late-payment charges, needs no authorisation (§ 25(3)(a)); other obligations under the Act may still apply to it. Agreements concluded before 20 November 2026 remain governed by the previous rules, except for listed provisions (§ 58(1) and (2)).

What to do now

Little time remains until 20 November 2026 for a change of this scale, particularly if authorisation or redesigning credit assessment is needed.

Three steps make sense regardless of the final assessment:

1. Determine whether you are a lender. Review every arrangement involving later or split payment: your own instalments, partner deferred payment, leasing and employee loans.
2. Review advertising and pre-contractual information. Cost warnings and standard information forms concern content and timing, not graphics alone.
3. Examine the default process. A separate change already applies: since 2024, consumer protection legislation has specific prohibited debt recovery practices, including times when debtors must not be contacted.

If your business offers deferred payments, instalments or consumer loans, send us a description of the model. The answer to the first question, whether you are a lender and what follows, determines how much work remains before November.