Regulatory AlertsFrance: lending & credit regulation
RegulatedStrict licensing for consumer credit; SME lending largely unregulated; BNPL under ACP
- Lead regulator
- ACPR (Prudential Control and Resolution Authority)
- Also involved
- DGCCRF (Consumer Code/BNPL) · CNIL (Data Protection) · ACPR (Prudential)
- Core law
- French Monetary and Financial Code (CMF)
- Entry capital
- EUR 50,000 (Credit Manager)
- Approval timeline
- 6-12 months for Credit Manager authorization
- Customer assets
- Segregated accounts required for Credit Managers
- Data protection
- GDPR + Loi Informatique et Libertés · CNIL
- Sandbox
- No
Consumer lending is strictly regulated under the CMF, requiring authorization as a 'Credit Manager' (Gesteur de Crédit) supervised by the ACPR. SME and commercial lending are generally unregulated unless structured as consumer credit. The BNPL sector is newly regulated under the 2022 Consumer Code, supervised by the DGCCRF and ACPR. Microfinance and P2P lending operate under specific, distinct regimes.
Which licence do you need?
| Your activity | Requirement | Capital | Timeline | Authority |
|---|---|---|---|---|
| Consumer lending | LicenceCredit Manager (Gesteur de Crédit) Requires good repute, professional insurance, and segregation of funds. | EUR 50,000 | 6-12 months | ACPR |
| SME / commercial lending | Unregulated Commercial lending to SMEs is generally unregulated. | — | — | — |
| Microfinance | LicenceMicrocredit Organization Specific authorization for microcredit organizations under CMF. | — | — | ACPR / Ministry |
| Buy-now-pay-later | LicencePayment Institution BNPL providers must hold a Payment Institution license under PSD2. | EUR 20,000 | 3-6 months | ACPR |
| P2P lending platform | LicenceInvestment Service Provider (ISP) P2P platforms providing investment services require AMF authorization. | EUR 125,000 | 6-12 months | AMF / ACPR |
| Credit bureau / scoring | RegistrationCredit File Processor Must register with CNIL and comply with data protection laws. | — | — | CNIL |
| Debt collection | LicenceDebt Collector Debt collection activities require specific authorization under CMF. | — | — | ACPR |
New — what changed recently
- 2022-01-01Consumer Code Amendment — BNPL services explicitly regulated under the Consumer Code, requiring transparency and responsible lending checks.
- 2021-01-01EBA Guidelines Implementation — ACPR implemented EBA guidelines on credit risk mitigation and expected credit losses for IRB approach institutions.[1][2]
- 2020-03-01Mortgage Risk Reporting Update — ACPR updated residential mortgage risk reporting frameworks, replacing CREDITHAB table with new annexes.
Market-entry checklist
- 1Secure ACPR AuthorizationApply for Credit Manager status with EUR 50k capital and professional insurance.
- 2Establish Segregated AccountsSet up dedicated client fund accounts as mandated by CMF for credit managers.
- 3Register with CNILComplete mandatory data protection registration for any credit file processing.
- 4Obtain Payment LicenseSecure Payment Institution license from ACPR if offering BNPL services.
- 5Comply with Consumer CodeImplement responsible lending checks and transparency disclosures for all consumer credit.
Sources
- Implementation of EBA guidelines on credit risk mitigation techniques for institutions applying the IRB approach with their own LGD estimates (EBA/GL/2020/05) · 2020-10-14
- Compliance with EBA Guidelines on credit risk management and expected credit losses accounting by credit institutions (EBA/GL/2017/06) · 2017-11-17