CCD2 and auto leasing: what changes in november 2026 for captive lenders and credit institutions

In 2024, 66% of new vehicles financed by private individuals were acquired through leasing, whether as a hire-purchase (LOA) or long-term rental (LLD) arrangement (UFC-Que Choisir study, April 2026).

The French transposition of CCD2 (the new Consumer Credit Directive) will take effect on 20 November 2026 and will bring about far-reaching changes in auto leasing, fundamentally reshaping the vehicle financing market.

Hire-purchase (LOA) now squarely in CCD2's scope

Under CCD2, hire-purchase agreements are explicitly brought within the scope of consumer credit regulation. In practical terms, this means:

A systematic and documented affordability and creditworthiness assessment
Application of usury rate caps and early repayment rules: which could significantly disrupt the economic model of this type of leasing
Standardised pre-contractual information: through the SECCI document
Strict regulation of advertising and digital customer journeys

These requirements demand a thorough overhaul of origination processes, scoring tools, and customer journeys.

Long-term rental (LLD): out of scope today, but for how long?

Long-term rental remains, for now, outside the directive's perimeter. However, the market momentum is undeniable: volumes surged by 67% in a single year (UFC-Que Choisir study, April 2026), driven by growing consumer demand for flexible arrangements.

This success naturally calls for proactive thinking. Regulators' expectations regarding transparency and consumer protection do not stop at the boundaries of the current text. Players who build robust creditworthiness assessment practices into their LLD contracts today are positioning themselves ahead of the curve, and insulating themselves against tightening regulation to come.

What this means in practice for auto finance players

Beyond compliance, CCD2 raises a fundamental question: what data should underpin your customers' creditworthiness assessment?

Self-declared data is no longer sufficient. Assessment methods must rely on reliable, relevant, and auditable data, collected in real time, properly documented, and capable of withstanding regulatory scrutiny.

Banking data analysis has therefore become non-negotiable.

Algoan's solutions to support leasing players

Whether in-dealership or remotely, Algoan offers a suite of solutions based on banking data analysis, via Open Banking or document OCR, designed to meet CCD2 requirements while improving the quality of credit decisions.

Transaction Data: bank aggregation with completeness verification‍

Algoan collects and analyses the applicant's bank transaction data, verifying that all accounts have been properly shared. This completeness is essential to ensure a comprehensive and defensible creditworthiness assessment in the face of regulatory requirements.

Credit Insights: in-depth analysis of budgetary situation and financial behaviour‍

Drawing on aggregated banking data, Algoan provides a categorisation framework specifically designed for credit purposes and produces enriched indicators covering income, recurring expenses, existing financial commitments, and spending behaviour. A precise picture of the customer's actual financial situation, far beyond self-declared data.

Credit Score: explainable behavioural scoring‍

Algoan delivers a credit score calculated in real time, with GINI gains of between +35% and +65% compared to a traditional socio-demographic score. Every decision is traceable and justifiable, a core CCD2 requirement, and a genuine asset for customer relationships and risk management.

In Conclusion

CCD2 is not merely a regulatory constraint, it is also a powerful lever for innovation and transformation. For auto finance players who act now, it represents an opportunity to strengthen origination quality, reduce arrears, and build customer relationships founded on transparency.

Ready to prepare for compliance? Contact us!

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Christelle Diguet, Marketing, Communication & Design Director at Algoan.