Consumer Credit Directive Creditworthiness Assessment: Income Checks

The consumer credit directive creditworthiness assessment is the lender's duty, under Directive (EU) 2023/2225, to judge from relevant and accurate information on income, expenditure and other financial circumstances whether a borrower can repay, before credit is granted. National rules transposing the directive apply from 20 November 2026. For a file reviewer this turns "collect three payslips" into a different question: which field on which document has been compared with which field on another document or register, and what was done when they disagreed.

This article is for informational purposes only and does not constitute legal, financial, or regulatory advice. Regulatory references are accurate as of 24 October 2026. Consult a qualified professional for guidance specific to your situation.

What does the directive require, and what does it leave open?

Directive (EU) 2023/2225 replaces Directive 2008/48/EC and requires lenders to carry out the creditworthiness assessment on information that is relevant, accurate and proportionate to the credit. The text applies in Member States from 20 November 2026, after a transposition deadline of 20 November 2025 (Directive (EU) 2023/2225 on EUR-Lex). Article 18 sets the assessment duty and Article 19 deals with consulting databases.

The directive does not publish a list of documents. It states a result: the assessment must rest on information about income and expenditure that the lender can stand behind. That is why the same loan can be backed by a payslip in one lender and by bank data in another. What the lender cannot do is rely on an unverified declaration and call it an assessment.

Two points matter for the review desk. If a refusal comes from a database consultation, the consumer has to be told. And where the assessment uses automated processing, the consumer can ask for human intervention and an explanation of the decision. Both mean the reviewer's notes are read later by someone else, so the cross-checks need to be recorded field by field.

The UK left the EU system, so Directive 2023/2225 does not apply to a lender authorised only in Great Britain. It matters if you lend to consumers in the EU, or run a group with an EU entity. UK-regulated lenders work to the FCA's rules instead, covered below.

The cross-check matrix: field against field

A cross-check names one field on one document and compares it with one field on another document or register. The matrix below is the spine of a review procedure for consumer credit, whatever the country.

Rows 1, 2 and 7 decide most files. The declared income, the observed income and the observed outgoings are the three numbers the affordability calculation needs, and each has to come from a document the reviewer actually opened.

A cross-check proves two documents agree on a field; it does not prove that either document is authentic, and it does not by itself prove the borrower can repay. Keep that distinction in the file note.

What the reviewer does when fields disagree

A mismatch is a finding, not a verdict. Sort findings into three outcomes and write the outcome next to the check.

1. Explained and documented. A name differs because of a marriage, and a marriage certificate or updated ID is supplied. Close the finding and attach the evidence.
2. Explained but not documented. The applicant says a bonus was paid in cash. Do not count it. Assess on the documented income only.
3. Unexplained or contradicted. The employer on the payslip cannot be matched to the account credit. Escalate to a second reviewer; do not approve on the strength of a verbal answer.

If a finding changes the affordability result, the credit decision follows the corrected figure. If the file no longer supports an approval, the reasoning in the note has to be understandable to the consumer, because automated or semi-automated decisions can be challenged under the directive's human-intervention right.

Market view: what applies in the United Kingdom

The FCA requires consumer credit firms to base the creditworthiness assessment on sufficient information that enables a reasonable assessment, obtained from the customer and, where necessary, from a credit reference agency. CONC 5.2A states that the extent of the assessment must be proportionate to the individual circumstances, including the cost and total amount payable (FCA Handbook, CONC 5.2A).

The Financial Ombudsman decisions that apply these rules use the same logic as the matrix: take reasonable steps to determine or reasonably estimate current income, and do so in proportion. A small short-term loan does not need the file a large loan needs, but the lender must be able to show why the checks it made were enough.

For UK files the usual documents are the payslip, the P60 for employees and the SA302 tax calculation for the self-employed. GOV.UK explains how to get an SA302. Rows 1 to 4 of the matrix map directly onto them: declared income against payslip, payslip against bank credit, payslip year-to-date against P60. Our guide to income consistency across payslip, tax document and bank statement walks through the UK fields one by one.

An EU-facing lender should note that a credit reference agency report shows what has been reported about the applicant's borrowing. It says nothing about current income, so it never replaces rows 1 and 2.

What users on forums actually ask

Threads on consumer finance forums and subreddits about credit applications return to the same few questions, and the answers follow from the matrix.

"The lender asked for three months of bank statements even though I sent payslips. Is that normal?" Yes. The payslip comes from the employer; the statement shows what arrived. Row 2 compares them, and a lender who skips it is relying on one party's paper.

"My payslip name is slightly different from my passport. Will I be rejected?" Usually not. A spelling variant is a query (row 5). A different date of birth is the one that stops a file.

"I am self-employed with irregular income. What do they look at?" Tax documents and the statement. Because there is no payslip, rows 2 and 4 carry the weight: the annual tax figure against the money that actually arrived.

Applicants also describe the process as "they want everything". The directive's emphasis on proportionate information is a useful answer: the lender should ask for what it needs to resolve each cross-check, and no more. Collecting a full year of statements when three months settle the question creates data-minimisation risk under the GDPR without improving the assessment.

Recording the assessment so it survives a challenge

The file should let a person who was not there reconstruct the decision. Record, for each cross-check, the two fields compared, the values found, the date of each document, the outcome (agree, explained, unexplained) and the reviewer. Record which databases were consulted and when.

Dates carry weight. A payslip is stale when a more recent one exists and the applicant has not supplied it. A bank statement that ends weeks before the application date cannot show the current salary credit. Set maximum ages in the procedure and apply them mechanically, so reviewers do not judge each case by feel.

When part of the comparison is automated, keep the comparison output with the file: extracted values, matched fields, flagged differences. Automation reads and compares fields faster than a person does. It does not decide the finding; the reviewer does. For how CheckFile approaches data handling, see our security page.

Pre-decision checklist

• Every cross-check in the matrix has a recorded outcome, including "not applicable".
• Declared income, observed income and observed outgoings each trace to a named document.
• Names and dates of birth are consistent, or the variant is explained with evidence.
• Existing credit commitments declared have been compared with the register or bureau result and the statement.
• No document is older than the maximum age in the procedure.
• Any change to the affordability result is noted with the reason.
• A refusal based on a database result has been communicated to the consumer.

To see how a lender or broker can run these field comparisons across a whole file, see our solution for credit and financing files. For the wider framework, read the document compliance guide, and for the lender-side process before a decision, how UK lenders validate income documents. Pricing is on the pricing page.

FAQ

When does the Consumer Credit Directive 2 apply?

National laws transposing Directive (EU) 2023/2225 apply from 20 November 2026, with transposition due by 20 November 2025. Check your Member State's transposing text, because the directive itself is addressed to States, not lenders.

Does the directive list the income documents a lender must collect?

No. Article 18 requires an assessment based on relevant and accurate information on income and expenditure, proportionate to the credit. The lender chooses the documents, and the choice has to be defensible.

Does it apply to lenders in the UK?

Not to a lender authorised only in Great Britain. UK lenders follow the FCA's CONC 5.2A. A group lending to EU consumers must meet the directive for those customers.

Can a cross-check prove a payslip is genuine?

No. It shows that the payslip agrees with the bank credit, the tax figure and the identity details. A well-made false document can agree with itself, which is why independent sources such as the bank statement and official records matter.

What should happen when income on the payslip and the bank credit differ?

Treat it as a finding. Request a further statement or an explanation with evidence, assess on the documented figure, and escalate if the employer cannot be matched.