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ACCIS

ACCIS represents organisations that manage data to assess the financial credibility of consumers.

Lobbying Activity

Meeting with Arba Kokalari (Member of the European Parliament, Rapporteur)

23 Oct 2025 · AI in Financial Services

ACCIS calls for AI Act simplification and implementation delay

14 Oct 2025
Topic — The Commission is seeking input on simplifying digital regulations and reducing business burdens.
Message — ACCIS requests removing redundant AI Act requirements already covered by existing financial and data laws. They also suggest delaying compliance until 24 months after technical standards are published.12
Why — This would reduce administrative burdens and provide legal certainty for credit information suppliers.34
Impact — Implementation delays could hinder the goal of achieving genuinely trustworthy AI systems.5
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Meeting with Mattias Levin (Acting Head of Unit Financial Stability, Financial Services and Capital Markets Union)

2 Jul 2025 · Deployment of AI in financial services

Meeting with Maria Raffaella Assetta (Head of Unit Financial Stability, Financial Services and Capital Markets Union) and Insurance Europe and

4 Mar 2025 · EU financial services industry associations debrief on EU-UK Financial Regulatory Forum

ACCIS urges harmonized data rules to boost cross-border credit

31 Jan 2025
Topic — The consultation concerns the further development of the European Union single market.
Message — ACCIS requests legally secure data-sharing with consistent application of data protection rules. They call for a risk-based application of rules to simplify regulatory burdens. They also believe a more comprehensive picture of borrower financial position is vital.123
Why — Consistent rules provide legal certainty and lower costs for cross-border credit operations.4
Impact — Consumer privacy may be compromised by the push for more comprehensive data collection.5
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Meeting with Lucilla Sioli (Director Communications Networks, Content and Technology) and

27 Jan 2025 · Clarification of the scope of the definition of AI systems

Meeting with Maria Raffaella Assetta (Head of Unit Financial Stability, Financial Services and Capital Markets Union) and Insurance Europe and

9 Jan 2025 · EU-UK Financial Regulatory Forum

Meeting with René Repasi (Member of the European Parliament) and European Banking Federation

17 Oct 2024 · Conference - European Court of Justice - Access to requests for preliminary ruling for interested third parties

ACCIS urges uniform GDPR enforcement to support credit markets

8 Feb 2024
Topic — A review of the General Data Protection Regulation six years after its implementation.
Message — ACCIS requests more uniform enforcement by national authorities to ensure a level playing field. They seek clear guidance on using legitimate interest for processing financial data. They also oppose classifying credit scoring as high-risk artificial intelligence.123
Why — Clearer rules would reduce administrative costs and allow for more efficient automated assessments.4
Impact — Consumers lose transparency as the industry seeks to protect trade secrets related to scoring logic.5
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ACCIS Demands Clarity on Credit Data in FIDA Proposal

31 Oct 2023
Topic — A consultation on the proposed framework for wider sharing of financial customer data.
Message — ACCIS urges the Commission to clarify the ambiguity regarding the inclusion and exclusion of data for creditworthiness assessments. They call for better alignment between conflicting recitals and articles within the framework.12
Why — Clarifying the framework protects existing, well-functioning credit reporting systems from regulatory confusion.3
Impact — Consumer groups risk being targeted with unfair or discriminatory credit offers if exclusions are removed.4
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Credit bureau association ACCIS seeks clarity on EU Data Act

13 May 2022
Topic — New European legislation to regulate data access and use across sectors.
Message — ACCIS requests explicit clarification on how data sharing rules apply to credit bureaus. They seek a watertight definition of when governments can access private business data. They also demand consistent interpretation with existing data protection laws.123
Why — Precise definitions would provide legal certainty and shield their proprietary data from government requests.4
Impact — Public authorities lose broad powers to collect private data during crises.56
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Meeting with Maria-Manuel Leitão-Marques (Member of the European Parliament, Shadow rapporteur)

12 May 2022 · CCD

Meeting with Svenja Hahn (Member of the European Parliament, Shadow rapporteur) and Orgalim – Europe's Technology Industries

27 Apr 2022 · Artificial Intelligence Act (AIA)

Response to EU single access point for financial and non-financial information publicly disclosed by companies

27 Mar 2022

Please find attached the comments from ACCIS. ACCIS is the voice of organisations responsibly managing data to assess the financial credibility of consumers and businesses. Established as an association in 1990, ACCIS brings together more than 40 members from countries all over Europe as well as associates and affiliates across the globe.
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Meeting with Petar Vitanov (Member of the European Parliament, Shadow rapporteur)

17 Feb 2022 · AI Act

Meeting with Deirdre Clune (Member of the European Parliament, Shadow rapporteur)

27 Jan 2022 · Artifical Intelligence Act

Response to Consumer Credit Agreement – review of EU rules

1 Sept 2021

ACCIS represents the largest group of credit reference agencies in the world. ACCIS brings together 40 members across 28 European countries and 11 associate and affiliate members from all other continents. ACCIS broadly welcomes the Commission’s proposal to review the Consumer Credit Directive (CCD). We think that the revised rules increase the level of consumer protection, facilitate access to consumer credit across the EU and address the key, specific challenges brought on by the COVID-19 crisis. In particular, we welcome: • The improvements in consumer protection that will come from extending the scope of the CCD. • The clarification that the assessment of creditworthiness should be “thorough” and be based on “information on the consumer’s income and expenses and other financial and economic circumstances” (Article 18(2)). Concerning the information that should be used to perform a creditworthiness assessment, we also welcome the alignment of the CCD with the text in the Mortgage Credit Directive (MCD) and the reference that Recital 47 makes to the European Banking Authority Guidelines on loan origination and monitoring (EBA/GL/2020/06). • The recommendation for creditors to consult credit databases to assess the credit status of a consumer in Recital 49. At the same time, we believe that there is still some room for improvement concerning the performance of creditworthiness assessments and the provisions concerning access to, and content of credit databases. Please read more detailed comments in the attached file.
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Response to Requirements for Artificial Intelligence

4 Aug 2021

The Association of Consumer Credit Information Suppliers (ACCIS) represents the largest group of credit reference agencies in the world. ACCIS brings together 40 members across 28 European countries and 11 associate and affiliate members from all other continents. Building on the vast experience of the credit reference industry with data management and data analytics, ACCIS acknowledges the Commission’s efforts to address both the benefits and challenges of AI in its draft regulation laying down harmonized rules on this technology. We believe, however, that more work is needed to strike the right balance between promoting innovation and protecting European citizens and their rights. We fear that the current draft adopts a disproportionate approach that could curtail the use of socially beneficial applications of AI/ML, in particular as regards creditworthiness assessments and credit scoring. We have identified three main critical issues in the draft Act and recommended solutions: 1. the definition of AI systems should be narrowed so that it does not include low risk, understandable and explainable techniques such as logistic regression; 2. AI for credit scoring and creditworthiness assessments should not be deemed high-risk because borrowers are already adequately protected by existing legislation and regulations; 3. the concept of creditworthiness should be clarified; We would like to also share our views and recommendations on three additional issues: 4. the proposed obligations on providers and users of AI systems intended to be used to evaluate the creditworthiness of natural persons or establish their credit score are not appropriate; 5. the role of voluntary codes of conduct should be strengthened; and 6. the governance framework should ensure harmonized supervision and enforcement of obligations. Please read more detailed comments in the attached file.
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Response to Legislative framework for the governance of common European data spaces

1 Feb 2021

The Association of Consumer Credit Information Suppliers (ACCIS) and the Federation of leading Business Information Services Providers (FEBIS) appreciate the opportunity to comment on the European Commission’s proposal for a Data Governance Act. ACCIS and FEBIS represent a category of specialized intermediary that administers a mechanism enabling credit information collection, processing and further disclosure to users of data, as well as value added services based on such data. That intermediary is known as a Credit Reporting Service Provider (CRSP). We agree that the European Union needs to strengthen data sharing mechanisms, to increase the availability of data and thus facilitate the creation of new products and services for the benefit of European consumers and businesses. ACCIS and FEBIS welcome the Data Governance Act as we see this initiative as a step in the right direction. Concerning the definition of intermediation services under Article 9 (1)(a), we think that it is very broad and may, theoretically, cover almost any facilitation of data exchange between data holders and potential data users. We would recommend that intermediation services are defined more clearly in the articulated text, with basis on the exemptions mentioned in the recitals. We support, in particular, that the DGA will open up data held by public sector bodies which is currently unavailable, including for reasons of commercial or statistical confidentiality. The provisions on reuse of “protected” data held by public sector bodies are, however, not ambitious enough. We think that public sector bodies should be subject to an obligation to open up currently unavailable data. This would create a right for companies to access such data. Please find our joint consultation response attached for further comments.
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Response to Commission Implementing Decision on standard contractual clauses for the transfer of personal data to third countries

9 Dec 2020

Established in Dublin in 1990, the Association of Consumer Credit Information Suppliers (ACCIS) represents the largest group of credit reference agencies in the world. ACCIS brings together 42 members across 28 European countries and 10 associate and affiliate members from all other continents. Please find our feedback on this consultation in the attached PDF document. Thank you for your attention.
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Response to Consumer Credit Agreement – review of EU rules

28 Aug 2020

The Association of Consumer Credit Information Suppliers (ACCIS) represents the largest group of credit reference agencies (CRAs) in the world. CRAs are independent organisations that securely hold data about consumers. Lenders use the information held by CRAs to assess the creditworthiness of borrowers. ACCIS welcomes the opportunity to comment on the Commission’s plans to review EU rules governing consumer credit agreements. Our comments are attached.
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Meeting with Valdis Dombrovskis (Executive Vice-President) and

28 May 2020 · COVID-19 relief measures

Meeting with Valdis Dombrovskis (Executive Vice-President) and

28 May 2020 · COVID-19 relief measures

Response to Evaluation of the Consumer Credit Directive

27 Jul 2018

ACCIS, the largest group of credit reference agencies (CRAs) in the world, would like to share three reflections on the evaluation roadmap of the Consumer Credit Directive (CCD). a) Data for creditworthiness assessments and responsible lending As third parties between the interest of lenders and borrowers, CRAs provide information to support the evaluation of the borrowers’ ability to repay, thereby contributing to reducing asymmetries between those parties and to supporting sound lending processes. CRAs are not involved in how information is used by lenders – this is for them to decide, in the context of a consumer’s credit application. Hence, our main interest lies in the recitals and articles in the CCD that relate to the provision of information for creditworthiness assessments and the verification of the borrower’s information against our databases. In its Roadmap, the Commission reports that the evaluation of the CCD will assess ‘how the CCD works together with other legislation in the field of retail financial services, consumer protection and data protection’. In that regard, there are differences between the CCD and the Mortgage Credit Directive (MCD) concerning the data inputs that should be used in creditworthiness assessments: whereas the CCD refers to ‘sufficient information’ (Article 8), the MCD refers to ‘all necessary and relevant factors’ (Recital 55, Article 18.1). ACCIS would like to invite the Commission to evaluate how the outcomes of the creditworthiness assessment obligation provided for in the CCD - adopted before the outbreak of the financial crisis and in the early digitalization days - compare with the outcomes of the ‘strengthened creditworthiness assessment’ (Recital 22) included in the MCD and, in particular, whether the potential inadequacy of the factors below may have led to a less than optimal performance of the CCD in effectively promoting responsible lending and protecting consumers (Recital 26): • the information used in creditworthiness assessments i.e. depth of data; • the coverage of credit products considered in the assessment i.e. breadth of data; and • the consultation / verification of external databases. ACCIS would be glad to work with the Commission to explore how to enhance EU citizens’ access to affordable finance and the role that ‘relevant’ data, including positive data, can play in preventing over-indebtedness and facilitating financial inclusion. b) Robust inter-services coordination / cooperation We support that the evaluation of the CCD is led by the Consumer Policy Unit. We think, however, that the issues relating to our industry should not be read exclusively from a consumer protection-privacy perspective. In the past, we have noticed that you coordinate / cooperate on consumer credit issues with other Units within the Commission, such as the Retail Financial Services Unit (DG FISMA). We would recommend that coordination / cooperation to continue throughout the evaluation exercise. c) Expert Group on Credit Histories and World Bank General Principles for Credit Reporting We would like to recall the recommendations from the Expert Group on Credit Histories (EGCH), that was disbanded in 2009, after presenting its report on how to maximise credit data circulation in the EU whilst ensuring a high level of consumer protection as a relevant source for the CCD evaluation exercise. Many of their recommendations are still valid, others have been overtaken by subsequent developments, such as the MCD and the General Data Protection Regulation (GDPR). In order to further support the evaluation of the CCD and to prepare a potential review of the text, ACCIS recommends the re-establishment on an ‘EGCH 2.0’, whose task would be to review and update the previous recommendations. We would also invite you to take into account in the evaluation of the CCD the General Principles for Credit Reporting prepared by the World Bank in 2011.
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Meeting with Wojtek Talko (Cabinet of Commissioner Věra Jourová)

22 Jan 2018 · GDPR

Meeting with Elina Melngaile (Cabinet of Vice-President Valdis Dombrovskis) and Bistoncini Partners and CRIF SpA

22 Jan 2018 · retail financial services, fintech

Meeting with Kevin O'Connell (Cabinet of Commissioner Věra Jourová)

29 May 2015 · Data Protection Regulation