Interest-free consumer loans – those provided without interest or fees – are currently almost entirely excluded from the scope of the Consumer Credit Act (CCA). Only a few initial provisions of the Act apply, along with rules governing creditor conduct in the event of consumer default. This broad exemption applies regardless of whether the loan is classified as mortgage or non-mortgage consumer credit.

However, with the transposition of the European Consumer Credit Directive (CCD2) into Czech law, the approach to interest-free loans will change significantly.

What change in scope will the amendment to the CCA introduce?

The CCD2 abolished the exemption for interest-free consumer loans. From the effective date of the amended CCA (November 2026), providers of formerly exempt interest-free loans will face new obligations. In particular, they will be required to:

- obtain a licence to operate under the CCA;

- fulfil information duties towards consumers and assess their creditworthiness;

- submit to supervision by the Czech National Bank (CNB).

The amendment includes an exemption for retail merchants who provide consumer loans as a means to support their core business. However, the loan must:

- be a linked credit;

- take the form of deferred payment for goods or services;

- be interest-free and free of any other charges;

- be provided directly by the merchant, with no third-party involvement.

To qualify for the exemption, the following factors must also be present in the correct combination:

- the size of the merchant;

- the sales method (e.g. remote/online sales);

- the loan term (between 14 and 50 days).

For completeness, it is worth noting the exemption from scope for providers of interest-free housing loans. For them, nothing will effectively change – the exemption is based on a different consumer directive (the Mortgage Credit Directive – MCD) and is currently covered under the CCA's general exemption for all interest-free loans.

Author: Petra Bernklau