FECIF Editorial | September 2026

Credit intermediation has become an important part of European retail lending markets, particularly in mortgage finance. Yet, despite the common framework established by the Mortgage Credit Directive (MCD) and the Consumer Credit Directive (CCD), national markets still differ considerably in their structure, regulatory environment and level of digitalisation.

It was against this background that FECIF recently conducted a survey covering ten European markets. Our aim was to gain a clearer picture of how credit intermediation works across Europe and, more importantly, to identify the common trends and challenges behind sometimes very different national market structures.

The findings point to a clear key message. Credit intermediaries have become an integral and increasingly important part of mortgage distribution in Europe, yet their role is not reflected in the European regulatory framework to an extent corresponding to their actual importance in the market. Future EU regulation should therefore better recognise the role of credit intermediaries within the European mortgage distribution system and provide a framework that enables them to perform this role effectively.

This does not mean compromising on consumer protection. Rather, it means combining a high level of consumer protection with regulation that is proportionate, operationally workable and capable of supporting further digitalisation.

The market evidence behind this conclusion is significant. In several European markets, more than half of mortgage lending is already distributed through intermediaries, while their share is substantial in a number of others. This is important not only in terms of market volumes. Intermediaries help borrowers compare financing alternatives and navigate a mortgage process that is becoming increasingly complex.

There is, of course, no uniform European market structure. Independent and tied intermediaries coexist, and national markets generally show a mixed structure of larger and smaller market participants, although large intermediary networks tend to play the dominant role. Online comparison platforms are also becoming an increasingly important part of the credit distribution landscape.

This development raises an important regulatory question. Credit intermediation is already an extensively regulated financial activity. Licensing or registration, professional qualification requirements, disclosure obligations, professional indemnity insurance and ongoing supervision are common features across Europe. The issue is therefore not a lack of regulation. Rather, the challenge is to ensure that the regulatory framework remains proportionate and operationally workable as its complexity increases.

This matters particularly because compliance costs, documentation requirements, overlapping obligations and differences in national implementation can create significant operational burdens. Strong consumer protection must remain at the heart of European financial regulation, but it should go hand in hand with a framework that allows intermediaries to perform their role efficiently.

Remuneration is part of the same discussion. Lender-paid, percentage-based commissions remain the predominant model across Europe, while statutory commission caps appear to be the exception rather than the general approach. Transparency and consumer protection should be accompanied by legal certainty and due consideration of the economic sustainability of intermediary services.

Digitalisation presents another important challenge — and opportunity. Progress is evident across Europe, but it remains uneven. Comparison, prequalification and application submission are increasingly digital, while many mortgage processes still depend on fragmented systems and manual exchanges of information. The next stage of development will therefore require better integration between lenders, intermediaries and public systems. Interoperable infrastructures, appropriate API solutions and secure access to relevant public databases could reduce unnecessary documentation, shorten processing times and ultimately improve the experience of borrowers.

All of this is particularly relevant as we look towards the future development of the Mortgage Credit Directive. The MCD established an important common foundation for mortgage credit regulation and consumer protection in Europe. But the market has continued to evolve since its adoption. Credit intermediaries have become increasingly important in mortgage distribution, digitalisation is changing the way the market operates, and significant differences between national markets remain.

A future review of the MCD therefore offers an opportunity to respond to these developments. Greater harmonisation where appropriate, proportionate regulatory requirements, reduced unnecessary administrative burdens and support for further digitalisation should be important considerations in this process. Better access for authorised intermediaries to relevant public databases and financial infrastructure, together with greater interoperability between lenders and intermediaries, could make mortgage processes more efficient for both the industry and consumers.

There is no single European model of credit intermediation, nor does there need to be one. What is important is that the continuing transformation of the market is properly understood and reflected in the European policy debate.

For this reason, FECIF will work to ensure that the perspective and interests of credit intermediaries are more clearly represented at European level. In the near future, we intend to initiate discussions with the relevant EU institutions and stakeholders and bring the experience of the credit intermediation sector more directly into the European regulatory debate.