The European Union’s NPL Directive harmonizes the regulations for handling non-performing loans and strengthens consumer rights. EOS shows how the requirements are being implemented locally by its local subsidiaries.
- Directive creates harmonised legal framework on the EU market for non-performing loans
- Expanded regulatory requirements including information and reporting obligations
- EOS Group coordinates exchange of best practices between its national subsidiaries
Occasionally, something that initially seems unremarkable can have far-reaching consequences. At the end of 2021, the EU Directive 2021/2167 on credit servicers and credit purchasers entered into force in Europe. Within the European Union, it is designed to provide a harmonised framework for the purchase and service of non-performing loans (NPLs). Currently, the directive generally referred to as the “NPL Directive” has been implemented into the national laws of the majority of member states, and is fundamentally changing the market as a result.
According to the NPL Directive, companies like EOS that are experts in receivables management and service non-performing loan portfolios need an authorization in the respective country – and must meet precisely defined requirements in respect of management, processes, and their interaction with consumers.
EOS is a byword for industry leadership, so compliance with statutory requirements and industry regulations is a given for the EOS Group. The company is working hard to implement the provisions of the national laws resulting from the Directive, and can already report numerous successes. “Operational responsibility for implementation lies with our national subsidiaries. But as a Group, we are coordinating the exchange of information and best practices and are available as the main point of contact,” says Freda Stockfleth, Senior Vice President Corporate Legal. It’s a good example of the synergies that result through the company’s internationality.
The NPL Directive at a glance
European Union
The EU Directive 2021/2167 on credit servicers and credit purchasers (NPL Directive) entered into force at the end of December 2021. It is designed to simplify the sale of non-performing loans for banks and harmonise the regulations for credit purchasers and credit servicers across the EU.
Implementation
The EU member states were obliged to implement the directive into their national laws by the end of 2023. Germany has done this by means of the German Secondary Credit Market Act (KrZwMG), which was published in the Federal Law Gazette on December 29, 2023. The majority of member states implemented the Directive later and a few have not implemented it now, more than 1.5 years after the set deadline. In February 2025, the EU Commission decided to refer seven member states to the European Court of Justice of the European Union for failing to implement the Directive in time. As of today, Spain and Portugal are the countries where implementation has not been finalised yet.
Importance for EOS
Within the framework of the NPL Directive, the EOS Group operates as both a credit purchaser and credit servicer in many European countries. In accordance with the directive, the majority of EOS national subsidiaries requires an authorization as a credit servicer from the respective supervisory body and must meet the corresponding requirements within its organization.
The basic idea behind the NPL Directive was to support the reduction of high stocks of non-performing loans in the balance sheets of banks within the EU. Previously, there was no common legal framework in EU countries for handling NPLs. The objective of the directive is therefore:
- To harmonise the regulations for credit servicers and credit purchasers across the EU,
- to simplify the sale of NPLs, including across national borders, and
- to strengthen the rights of consumers.
The new requirements to be met by credit servicers include:
- Rules of conduct for fair and transparent dealings with borrowers
- Information obligations towards borrowers
- Risk management and compliance processes and verification of internal control mechanisms
- Reporting obligations to the respective national supervisory body
For many companies operating in the receivables management segment, the establishment of and adherence to the new regulations require a comprehensive expansion of structures and processes, additional reporting, and extra compliance efforts. “The EOS Group is taking a proactive approach here: Several EOS national subsidiaries, including those in Germany, France, Denmark, Greece, Croatia, Belgium, and the Czech Republic, have already obtained their authorizations,” says Stockfleth (as of: July 2025).
In other countries like Austria and Slovakia applications have been submitted.
Two national subsidiaries show how EOS companies are meeting the requirements of the NPL Directive at local level.
The protection of consumers as emphasized by the directive is a top priority for us.
Greece
In Greece, the directive has been implemented through Act 5072/2023 and other provisions that have been in force since December 2023. This resolved critical questions on the legal representation of credit servicers and simplified various processes. However, there were still considerable challenges to be mastered.
There are now stricter regulatory requirements e.g., with a view to the fair treatment of borrowers, including clear communication about debt collection processes, the protection of their rights, and data privacy mechanisms. Credit servicers must apply for a license and submit regular reports to the Greek National Bank and the Ministry of Economic Affairs. Likewise, advanced risk management systems have to be developed to identify and mitigate the risks associated with NPL portfolios.
EOS Greece was very quick to deliver results: “We obtained our new servicing license at the end of June 2024 and updated our online systems like the payment portal for consumers,” says Anthony Messados, Managing Director EOS Greece. To this end, in accordance with requirements, the Greek national subsidiary developed a personalized information system that provides borrowers with up-to-date information, e.g. detailed records of due amounts, costs or the interest rate applicable.
Many of the new provisions were already covered by the EOS Group, so we only had to make a few changes at our company.
Denmark
Denmark transposed the NPL Directive into Danish law in December 2023. Peter Hægerstrand Jensen, Managing Director EOS Denmark, identifies both challenges and opportunities in the new law. “On the one hand, the authorization process for a license as a credit servicer represented an extensive and intensive workload.” But it was worth it: EOS Denmark received its license from the Danish supervisory body in June 2024.
Furthermore, the documentation of compliance and governance processes involved much more paperwork than before, even though EOS Denmark had already placed a strong emphasis on this in the past.
On the other hand, the new rules also opened up new opportunities – because Danish regulations had previously hindered banks from selling portfolios. “These obstacles were eliminated when the directive came along. This is why in future we expect an even greater volume of business,” says Jensen.
It will probably take a few more months until the NPL Directive has been implemented in all EU countries and the market really is harmonized. In many places, EOS national subsidiaries have shown how the directive can be implemented efficiently.
Would you like to know more about the NPL Directive and EOS? Feel free to contact us!
Carina Bonde
Corporate Communications & Marketing
Phone: + 49 173 2979331
Lara Flemming
Senior Vice President Corporate Communications & Marketing
