From November 20, 2026, a specific type of consumer credit falls under strict regulation. The “3 or 4 times without fees” contract and small loans under 200 euros will be subject to the same legal framework as traditional consumer credit. This shift changes how intermediaries operate, particularly those who do not qualify as banking intermediaries (IOBSP).
Defining the New Intermediaries
Under French financial law, an IOBSP is a professional who habitually mediates in banking and payment services for remuneration. These intermediaries are divided into four categories: brokerage agents, exclusive mandates, non-exclusive mandates, and mandates of mandates. To operate legally, they must register with ORIAS, a central registry.
However, not everyone who sells credit qualifies as an IOBSP. The law defines exceptions, particularly when intermediation is just a small part of a professional’s main activity. For decades, the thresholds for these exceptions remained high, often set at 20 transactions or 200,000 euros annually. These limits no longer fit the new reality of small, high-volume credit products.
The thresholds were raised significantly by decree in February 2026. Professionals conducting fewer than 1,000 operations annually or totaling less than 500,000 euros in credit volume are exempt from IOBSP registration. This creates a specific group of sellers: they handle credit as a side service but are not fully regulated intermediaries.
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The Training Mandate
The 2025 ordinance modifying the Consumer Code creates a specific training obligation for these non-IOBSP sellers. These are employees who explain credit terms and collect information for the “dialogue sheet” but are not registered intermediaries.
The training must cover five key areas. First, it must provide general knowledge on distributing consumer credit and identifying appropriate financing needs. Second, it requires understanding the rights and obligations of borrowers and their spouses. Third, it covers the diligence and explanations needed for proper customer information. Fourth, it addresses debt prevention measures. Finally, it covers the specific rules and sanctions related to credit law violations.
The content of the training is detailed. It requires understanding the characteristics of different credit products, such as loans, leases, and buy-now-pay-later options. Employees must be able to analyze financial figures like the annual percentage rate (APR) and total cost of credit. They also need to understand guarantee mechanisms and insurance conditions.
How and When Training Must Occur
The training can be delivered by the lending institution itself or by a registered training organization.
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Employers are responsible for ensuring their staff complete this training. They must also keep the proof of completion available for inspection. Furthermore, employers must provide regular updates if laws or regulations change, ensuring knowledge stays current.
Possible Sanctions
For offers made after November 20, 2026, the specific sanction is an administrative fine. This fine is set at 1,500 euros for individuals. Companies face a penalty of 7,500 euros. This amount applies for any violation of the training obligations in Article L. 314-25 of the Consumer Code.
Authorities have the power to increase these fines. They can apply a multiplier based on the number of contracts or consumers involved. This allows for significantly higher penalties in cases of repeated or widespread non-compliance.
Consequences for the Borrower
The lack of training can also have direct consequences for the borrower. While civil liability for the lender is difficult to prove, the borrower may face difficulties in claiming damages if they suffer harm due to a lack of proper information. The law requires lenders to ensure the “good execution” of obligations related to credit formation, meaning the borrower is protected by the lender’s compliance with these training rules.
