Banks: the Merchant Register to be launched on 13 July
OAM: greater consumer protection against over-indebtedness
From 13 July, banks and financial intermediaries will have three months to submit data relating to the merchants (i.e. large retail outlets, car dealerships, online sellers) with whom they have agreements. The Organisation of Agents and Brokers (OAM) will in fact be required to supervise these entities as well, for the purposes of consumer protection, thanks to the new ‘Register of merchants” provided for by Legislative Decree 212/2025 in implementation of the European “Consumer Credit Directive II” (CCD2).
What does the obligation entail and who does it apply to?
The EU Directive, in fact, aims to ensure a high level of protection and to promote the development of a single credit market, whilst also regulating new forms of credit provision. Banks and financial intermediaries will therefore be required to provide details of the merchants with whom they have entered into agreements for the provision of credit for the purchase of goods or services offered by the merchants themselves. They will therefore have to register on the OAM portal and obtain accreditation, before accessing the dedicated service which will be activated in September within the private area. Even merchants acting as creditors (i.e. those who supply goods or services and who directly enter into credit agreements as an ancillary part of their business, solely in the form of interest-free deferred payment) will also need to register on the portal to gain access to the private area, where they must complete an online form which must be digitally signed by the legal representative or by another authorised person.
The requirement therefore applies to large retail outlets that offer consumer credit either through agreements with lenders or independently. These chains must therefore register via the banks (or financial intermediaries) with which they have an agreement, or directly if they offer deferred payment terms on their own behalf. The Register in fact provides for two separate sections for these two scenarios. The following are exempt micro-enterprises or SMEs which, on an ancillary basis, grant specific-purpose loans or interest-free payment extensions, and where the consumer is charged only for late payment fees.
A gradual adjustment
According to industry professionals who took part in a survey carried out as part of the OAM-Prometeia 2026 Report, overall, compliance with the new regulations is not expected to entail radical changes, but will require some operational and procedural adjustments. This applies particularly to creditworthiness assessment processes and internal control systems. In this regard, the prevailing view amongst banks and financial intermediaries is that the implementation of the EU Directive will protect consumers in particular from the risk of over-indebtedness.
According to respondents, in fact, stricter assessment criteria lead to better quality of credit and strengthen customer protection measures. Further anticipated effects include a reduction in approval rates for certain categories of customers and longer processing times. With regard to the strengthening of the OAM’s supervisory powers, banks and intermediaries believe the main consequences will be an improvement in the reputation of the credit distribution market and greater confidence among consumers in the credit profession. The flip side of the coin would be an increase in costs due to greater organisational burdens arising from the need to comply with the new controls.

