Germany Introduces New Loan Broker Permit in 2026

Germany is set to implement a new regulatory framework for consumer loan intermediation with the introduction of permit § 34k of the Trade Regulation Act (Gewerbeordnung, GewO), effective November 20, 2026. This reform, prompted by the EU Consumer Credit Directive (EU) 2023/2225, aims to professionalize and specialize the role of loan intermediaries operating in the country.

The new regulation establishes a distinct licensing requirement specifically for the brokering of general consumer loans. Previously, such activities fell under the broader scope of § 34c GewO, which encompassed diverse financial and real estate services. The introduction of § 34k GewO signifies a move towards a more specialized and rigorous regulatory environment for consumer credit intermediaries.

Key changes under the new law include mandatory professional knowledge testing, mirroring requirements found in the regulation for mortgage loan intermediaries (§ 34i GewO). This testing will cover areas such as credit products, legal frameworks, consumer protection, and advisory duties. Additionally, registration requirements through the German Chamber of Industry and Commerce (DIHK) and ongoing professional development obligations will be introduced.

The legislation includes transitional provisions, such as an "old hands" clause that may exempt experienced intermediaries from the knowledge test if they apply for the new permit within a specified period and have been continuously active since January 1, 2021. The scope of § 34k GewO covers general consumer loans like installment and personal loans, excluding mortgage loans which remain regulated under § 34i GewO. Specific application procedures are still being finalized by the authorities.