What this guidebook covers
The Supreme Court declared an APR (TAE) of 26.82% usurious: the customer only repays the capital. Without correct pre-contract information the contract can be challenged, and the consumer authorities can fine up to €1 million. The finance company will then look for whoever sold the loan.
This guidebook covers 5 standards for dealers that arrange finance, with 12 checkpoints: the standard European information (INE) before signing, ads that show the APR, voluntary insurance and extras, interest rates that are not usurious, and preparation for the new Consumer Credit Directive (CCD2), due by 20 November 2026. The guidebook PDF is in Spanish.
The 5 consumer credit standards
| Code | Standard | Ideal fix time |
|---|---|---|
| CRE-01 | Pre-contract information | 72 hours |
| CRE-02 | Ads show the APR | 72 hours |
| CRE-03 | Voluntary insurance and extras | 72 hours |
| CRE-04 | Interest rates not usurious | 7 days |
| CRE-05 | CCD2 preparation | 30 days |
How to run a Spanish consumer credit compliance audit, step by step
- Confirm what applies. This covers dealers acting as credit intermediaries, who must also follow the finance company's instructions; the new directive changes the rules from 2026.
- Walk the site, standard by standard. Score each of the 12 checkpoints Pass, Fail or N/A. N/A only where the standard rules it out, with the reason recorded. Review 10 finance files, 10 finance ads, 10 contracts with extras, and the 10 highest APRs against the Bank of Spain average rate.
- Capture the evidence. A pass counts only with proof captured at the time of the audit: finance files with the signed INE, ad screenshots, contracts with extras, the table of offers and the CCD2 plan and training records.
- Give every fail an owner and a fix time. Record what you saw and who owns the fix. Each standard carries an ideal fix time, from 72 hours to 30 days, counted from audit submission (see the table above).
- Fix it, then prove it. The site fixes the cause and uploads proof of closure; the auditor checks the proof before closing the finding.
- Re-check at the next audit. Confirm closed findings stay closed, and look for the same fail at your other sites so one gap doesn't repeat across the network.
Who this guidebook is for
- Management: understand the risk of void contracts
- F&I managers: know what to hand over and when
- Auditors: review finance files and ads
A reference document, not legal advice. Fines and rules change: check the current text with the regulator or your legal adviser before acting.
