Why every lender has to check
The Consumer Credit Directive obliges a lender to assess your creditworthiness before granting credit, using sufficient information from you and, where necessary, from a credit database. The revised directive, which applies from 20 November 2026, makes the assessment stricter: it must be based on relevant and accurate information on income and expenses, it may not rely on social media or health data, and a loan may only be granted if the assessment shows you are likely to repay it. If a lender rejects you on the basis of a database search, it must tell you which database it used.
In practice the assessment has two parts. The lender verifies your income and fixed costs, from payslips, tax data or a bank-statement connection. And it consults the national credit register to see what you already owe and whether you have missed payments. The second part is where countries differ.
Netherlands: BKR
Stichting BKR in Tiel keeps the Dutch credit register. Every consumer credit of €250 or more with a term of at least one month is registered, whether or not you pay it on time: personal loans, credit lines, credit cards, buy-now-pay-later above the threshold, and mortgage arrears. Lenders are legally required to consult the register before granting consumer credit and to report every new contract.
A registration on its own is not negative; it simply shows the lender your current commitments. Problems are marked with codes: an A for arrears, and further codes when the debt is claimed, written off or settled. Registrations stay visible for five years after the loan is closed. You can request your own overview free of charge on the BKR website, and you have the right to have incorrect entries corrected.
France: FICP
France takes the opposite approach. The Fichier des incidents de remboursement des crédits aux particuliers, run by the Banque de France, records only payment incidents: two consecutive missed instalments, an unpaid balance after formal notice, or a debt-restructuring procedure. A person with three loans repaid on time appears nowhere. Lenders must consult the FICP before every credit decision and are, in practice, unable to lend to anyone listed.
An incident stays on file for up to five years, and is removed early once the debt is paid off and the lender reports it. A restructuring plan is recorded for its duration, up to seven years. You can check your own status at any Banque de France branch or through its online service, free of charge. A separate file, the FCC, covers unpaid cheques and withdrawn cards.
Germany: Schufa
Schufa is a private company, not a public register, and holds both positive and negative data on most adults in Germany: current accounts, credit cards, loans, mobile-phone contracts, and any unpaid claims that have gone through formal collection. From this it calculates a score, expressed as a probability of repayment, which lenders combine with their own models. Most negative entries are deleted three years after the debt is settled.
You are entitled to one free copy of your Schufa data per year under the GDPR, and to correction of wrong entries. Since German lenders rely on the score heavily, checking it before a large application is standard practice.
Finland: the positive credit register
Finland ran for decades on negative data only, through the payment-default register kept by Suomen Asiakastieto. Since April 2024 the Finnish Tax Administration also operates a positive credit register, to which every lender must report consumer loans and which every lender must consult before granting one. It shows your loans, their balances and instalments, and, with your consent, your income from the income register. A payment default in the negative register remains, as before, a near-certain rejection.
