The clock is ticking for the retail sector and new licensing requirements

On 20 November 2026, the new Consumer Credit Act and the Act on Activities Involving Mortgage Loans and Certain Other Consumer Loans (LVBK) will come into force. This introduces a new and comprehensive regulatory framework for a category of operators that have hitherto largely been outside the scope of supervision: for example, shops, retailers, car dealers and other businesses that offer credit to their customers but do not grant or broker credit as their main business activity.

These so-called ancillary credit providers and credit intermediaries – who grant or arrange credit without it being their main business activity – will, from the date of entry into force, be subject to supervision by either the Swedish Consumer Agency or the Swedish Financial Supervisory Authority. Which supervisory body is applicable is determined, among other things, by the size of the company and the type of credit granted or arranged.

Subsidiary credit intermediaries with more than 250 employees and an annual turnover exceeding EUR 50 million, or whose balance sheet total exceeds EUR 43 million per year, must apply for authorisation from and be subject to supervision by the Swedish Financial Supervisory Authority. Subsidiary credit providers are required to apply for authorisation regardless of size, but factors such as whether the credit involves interest or certain fees, the size of the company, the payment terms, and whether sales take place online or in-store may influence the assessment of whether the business requires authorisation.

Existing companies that have so far operated without a licence but are covered by the new regulations have until 20 November 2027 to apply for the necessary licence. New companies starting operations after the law comes into force must have a licence in place from day one.

In addition to the licensing issue, the new legislation tightens, among other things, the requirements regarding the knowledge and competence of staff who grant or arrange credit. The aim is to give consumers better opportunities to understand the credit agreement and their rights.

On 20 May this year, the Swedish Financial Supervisory Authority issued a consultation document containing proposals for new regulations and general guidelines. The proposals include new general guidelines on credit assessment – among other things, they clarify what information should be included in the credit assessment documentation and how this should be collected and verified. In addition, binding regulations are proposed regarding the content of licence applications, internal rules for operations, restrictions on variable remuneration linked to granted credit, and requirements for training and an approved knowledge test for relevant staff. The proposals can be viewed here. The Swedish Consumer Agency is expected to follow up with its own proposals in June.

Time is short – retailers and other affected businesses need to review their operations now and assess whether a licence is required. If a licence is deemed necessary, a number of measures must be taken to ensure both the possibility of obtaining a licence and ongoing compliance with applicable rules.

Lindahl regularly assists clients with matters relating to financial licences and the associated operating rules. If your business has any questions regarding the new regulations, please do not hesitate to contact us.