The consumer credit market in France is entering a phase of regulatory transformation. Ordinance No. 2025-880 of September 3, 2025, which transposes European directive 2023/2225, redefines the scope of offers subject to borrower protection obligations.
Mini-loans, split payments, interest-free loans: products that were previously loosely regulated are now falling under the consumer credit regime. Choosing a credit solution suitable for a financial project now requires understanding this new framework even before comparing rates.
What the September 2025 ordinance changes for choosing credit
The text expands the protective regime of consumer credit to several categories of financing that were previously exempt from usual controls. Mini-loans of less than 200 euros, certain deferred or installment payments, interest-free loans, and financing between 75,000 and 100,000 euros are now included in the scope.
In practical terms, an offer presented as a simple “three-time payment” on a merchant site potentially falls under the same legal regime as a traditional personal loan. Therefore, it is essential to verify the legal framework of each offer, including those that seem innocuous.
Starting November 20, 2026, the reform also imposes a more thorough assessment of the borrower’s creditworthiness on lenders, as well as a legal duty to provide free warnings when the credit presents specific risks. To effectively compare the credit solutions from Conseil Invest, this transparency obligation constitutes a full-fledged selection criterion.
A lender or intermediary that provides a detailed budget analysis offers an additional guarantee compared to an entity that only focuses on the displayed rate.
APR and actual cost of credit: beyond the nominal rate
The annual percentage rate (APR) remains the benchmark indicator for comparing credit offers. It includes interest, application fees, and any commissions. However, it does not always reflect the total cost borne by the borrower.
Borrower insurance, a often underestimated item
Insurance can significantly alter the actual cost of a loan. The Lemoine law allows for the cancellation of borrower insurance at any time, but only for residential or mixed-use mortgage loans. It does not apply to personal loans, auto loans, or consumer credit, including those intended for renovations.
This distinction has direct consequences on financing strategy. For a mortgage, the delegation of insurance and the competition of contracts remain possible at any time. For consumer credit, the insurance conditions negotiated at signing are more challenging to modify afterward.
- Compare the cost of insurance separately from the APR, as the guarantees and rates vary significantly from one institution to another
- Check if the insurance contract includes an annual cancellation clause, even outside the scope of the Lemoine law
- Request a simulation with and without insurance to measure the actual gap over the total repayment period
The issue of interest on financed insurance
A recent ruling from the CJEU (April 23, 2026, case C-744/24) ruled on the prohibition of charging interest on the amount of insurance financed as part of a loan. Field reports vary on how institutions apply this decision, but the principle established by the Court potentially reduces the overall cost for the borrower. When applying for credit, checking how insurance is integrated into the borrowed capital helps avoid hidden costs.
Targeted credit, personal loan, or debt consolidation: which structure for which project
The choice between targeted credit (linked to a specific purchase) and a personal loan (free to use) depends less on the amount than on the nature of the project and the desired level of protection.
Targeted credit offers additional legal security: if the sale is canceled, the credit contract is also canceled. For a car purchase or an identified piece of equipment, this contractual link protects the borrower. A personal loan, on the other hand, allows total freedom of allocation, which is suitable for multiple projects or expenses that are difficult to quantify in advance.
Debt consolidation: a restructuring tool, not additional credit
Debt consolidation combines several loans into one, with a reduced monthly payment and often an extended duration. The total cost generally increases with the lengthening of the duration, even if the monthly payment decreases. This solution is aimed at borrowers whose debt ratio approaches limits, not those seeking additional financing.
- Calculate the total cost of consolidation (cumulative interest over the new duration) and not just the monthly payment
- Check the early repayment penalties on existing loans before initiating the operation
- Ensure that the consolidation includes all outstanding amounts, including often forgotten revolving credits
Credit file and creditworthiness assessment: what weighs in the decision
With the November 2026 reform, the assessment of creditworthiness becomes more regulated. The lender will have to take into account the individual risk of the borrower more thoroughly, rather than relying solely on automated scoring based on generic criteria.
For the borrower, this means that the quality of the file weighs as much as the level of income. A comfortable remaining disposable income, the absence of repeated overdrafts, and the stability of fixed charges count in the analysis. Transparency regarding existing financial commitments (ongoing loans, recurring charges) facilitates obtaining favorable conditions.
The duty to provide warnings stipulated by the reform requires the lender to alert the borrower for free if the credit presents a risk concerning their situation. This mechanism, which will come into effect on November 20, 2026, changes the dynamics of the relationship: the lender becomes co-responsible for the suitability between the offer and the profile. Refusing to provide this warning could expose the institution to legal actions.
The landscape of consumer credit is restructuring around stricter transparency requirements. Comparing offers is no longer limited to the rate: the applicable legal regime, the handling of insurance, and the quality of the lender’s support have become full-fledged selection criteria.
