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

Slovakia’s consumer credit framework is changing for the first time in fifteen years. 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 to EUR 100,000, but the Act provides exceptions. Under § 1(2), this threshold does not apply to specified building loans and unsecured loans for renovating residential property; selected provisions of the Act may apply to other loans. The precise regime must therefore be determined by reference to the product, not merely its amount.

Some room remains for a genuinely interest-free, entirely fee-free deferred payment due within a very short period. 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 clearly warn that borrowing costs money. If it states an interest rate or cost information, it must include standard information such as APR, total credit amount, duration and total payable.

Pre-contractual information readable on mobile. Information is provided using the Standard European Consumer Credit Information form, with key elements on the first page and readable on a phone. 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. Health data and information obtained from social networks are expressly prohibited.

Rules for automated decisions. Where assessment is automated, consumers have rights to human intervention, an understandable explanation of the assessment and system, and review of the outcome. Scoring models should account for these rights from design.

Measures before recovery. Lenders are expected to address credit risk actively and early, through extending the agreement, changing its type, deferring payments, reducing interest or even partial debt forgiveness, rather than proceeding straight to recovery.

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. Transitional deadlines must be calculated for the specific entity and model, making this our first question with affected clients.

What to do now

Three months remain until commencement, a short period 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 first answer, whether you are a lender and what follows, is often short and determines how much work remains before November.