A customer calls about their credit card. They are three weeks behind, their hours at work have been cut, and they want to know what happens next.
Swedish law is about to ask more of the answer. On 20 November 2026 the new consumer credit act, Konsumentkreditlag (2026:1011), replaces the 2010 act. Several of its new duties are things an agent either says on a call or doesn’t.
From 20 November, a lender in Sweden must have routines to spot customers in financial difficulty early, and tell them where to get help with budget and debt. When a customer is behind on a payment, the lender must, where appropriate, offer an alternative to enforcement that changes the agreement. Both duties play out in conversations, so your calls are your evidence.
What changes on 20 November
The Riksdag passed the act on 27 May 2026. It implements the EU’s revised Consumer Credit Directive, Directive (EU) 2023/2225, which EU countries apply from the same day. In the government’s summary, credit checks get stricter, lenders must offer alternatives such as a lower rate or a deferral when a customer can’t pay, and more firms that offer or broker credit need a licence.
Five provisions of the act (government bill 2025/26:223) reach into a customer conversation:
| The duty | Where in the act | What it looks like on a call |
|---|---|---|
| Have routines to spot financial difficulty early. When you find it, tell the customer where to get budget and debt advice | Chapter 6, section 11 | The customer says they’ve lost their job. Does the agent tell them where to get budget and debt advice? |
| When a payment is late, offer, where appropriate, an alternative to enforcement that changes the agreement. Weigh the customer’s circumstances and ability to repay | Ch. 6, s. 12 | Does the agent ask about the situation and, where it fits, discuss options such as a deferral? |
| On request, explain the credit’s main features and the effects it can have | Ch. 3, s. 12 | The customer asks what happens if they miss a payment. Does the agent answer? |
| If the credit assessment was automated, on request, have a person review it and explain it | Ch. 3, s. 15 | “Can a person look at this?” Is there a route, and does the agent know it? |
| If credit is refused, tell the customer why, promptly, and where relevant where to get budget and debt advice | Ch. 3, s. 16 | “Why was I turned down?” |
One more applies to phone sales. A consumer is bound by a credit agreement only if they explicitly agreed to it (Ch. 4, s. 1). If your agents sell credit or limit increases by phone, the record of that clear yes matters.
“Where appropriate” is decided in a conversation
Section 12 doesn’t require an offer on every late payment. It requires the lender to weigh the customer’s personal circumstances and ability to repay, and to offer an alternative when that is appropriate. The examples in Article 35 of the directive include a longer term, deferred instalments, a lower rate, a payment holiday, partial repayments and partial forgiveness.
That weighing mostly happens on an arrears call, outbound or inbound. The call may be handled by your own team, a partner or an AI agent. If no one asks about the situation, the lender can’t show it weighed the customer’s circumstances.
Early detection works the same way. Section 11 asks for routines and guidelines. A customer who says “I’ve been off sick for two months” has told you something. A routine that depends on an agent hearing it and acting on it is only as good as the calls where it actually happens.
Who checks
Konsumentverket supervises the act, except for firms under Finansinspektionen’s supervision (Ch. 9, s. 1). The new licensing rules move more lenders and brokers into the second group. Konsumentverket can require information and inspect documents (Ch. 9, s. 2). Failing to give the explanations in Ch. 3, s. 12 counts as unfair under the Marketing Act (Ch. 9, s. 4).
If a supervisor asks how your routine for financial difficulty works, a policy shows what should happen. Your calls show what did.
Denmark and Finland on the same day, Norway later
Denmark’s implementing act, lov nr. 1322 of 20 November 2025, and Finland’s amendments also take effect on 20 November 2026. The details differ by country, but the forbearance and debt-advice duties come from the same articles of the directive.
Norway is not there yet. The directive is not yet part of the EEA Agreement: a draft decision to incorporate it is still under consideration. A Norwegian firm lending to consumers in Sweden, Denmark or Finland must still be ready there from 20 November.
A checklist for your calls
- Listen to your arrears calls. Pull twenty calls from last month where the customer was behind on a payment. Did the agent ask about the situation? Discuss an alternative? Mention budget and debt advice?
- Write down the signals. Lost job, illness, separation, “I can’t pay this month”. Decide what an agent must do when they hear one.
- Give agents the words. A short, plain line that points to budget and debt advice, which the customer’s municipality provides free.
- Add the duties to your scorecard. As yes or no criteria, each with the moment in the call that shows it: situation asked about, alternative discussed or the reason it wasn’t, debt advice mentioned when difficulty came up, explanation given when asked, human review started when the customer asked for one.
- Check the route to a person. If credit decisions are automated, make sure a review by a person exists, and that agents know how to start one.
- Hold partners and AI agents to the same bar. If an outsourcing partner or an AI agent handles your arrears calls, the same criteria apply. We’ve written about one quality bar for human and AI agents.
- Check your coverage. Say one call in twenty involves a customer in difficulty. At five reviewed calls per agent a month, about three agents in four won’t have a single one in their review. How many calls QA should review has the arithmetic.
Where Conversational Intelligence fits
Conversational Intelligence scores every call against your scorecard, including criteria like these. Every score links to the sentence, timestamp and speaker behind it, so a reviewer can check the evidence, and you can answer a supervisor’s question with calls rather than a policy.
What counts as appropriate for a given customer stays with your people and your credit policy. We’ll help you turn the new duties into criteria you can score.
