The Standard European Consumer Credit Information (SECCI) is not just a form: it is proof that the customer knew what they were signing. We design, review and make traceable all your pre-contractual documentation, in branches, at the point of sale and in digital channels.
Audit of your documentation
We reply within 24 h
Six workstreams on the same documentation package: the standardized information form, the contract it leads to, the explanations that go with it, the cost calculation, the channel through which it is delivered and the evidence left of all of it.
We check that the form includes every required section, that the figures match the contract it leads to and that the whole document is understandable to an average consumer with no financial knowledge. Format matters as much as content.
In digital channels, the question is not whether you delivered the information, but whether you can prove what the user saw, when they saw it and in which version. We design the delivery flow, the durable medium and the record that proves it.
We verify the calculation of the total cost, the treatment of fees and linked products, and how they are expressed in the form, the contract and the advertising, which must all say exactly the same thing.
Delivering the form does not exhaust the obligation. The lender must provide explanations that allow the customer to assess whether the product suits their situation. We script that conversation and the way it is recorded.
A term loan, a revolving credit line and a deferred payment cannot share the same form. We adapt the documentation package to the real mechanics of each product you sell.
Preparing the evidence file and the response to claims alleging a lack of pre-contractual information, both before the customer service department and in court.
The content of pre-contractual information is prescribed by law and identical for everyone. What changes radically from one channel to another is the ability to prove, years later, that it was delivered and that the customer was able to read it.
"A signature on a generic acknowledgment proves that something was delivered, but not always which version of the document, or how far in advance of signing the contract. That detail is exactly what is argued about in court."
"When the pre-contractual information and the signature happen in the same minute, in front of a sales assistant who is not employed by the lender, the requirement to provide it sufficiently in advance becomes hard to defend. It is the most exposed channel of all."
"Well designed, the digital channel is the most defensible: you can record which document was generated, when it was made available to the user and when they accepted. Poorly designed, it only stores a boolean that proves nothing."
"Recording the call proves the verbal explanations, but it does not replace delivering the information on a durable medium. They are two different obligations, and they should not be confused when designing the process."
Information to the consumer is not a single delivery: it is a sequence. Confusing one stage with another—or handling them all at once at signing—is the source of most of the defects that are later alleged.
Any advertisement that mentions an interest rate or cost figures must include a set of minimum information by means of a representative example, with the APR (TAE) highlighted. This also applies to websites, social media and comparison sites.
In good time before signing and on a durable medium. It must reflect the specific terms to be offered to that customer, not a generic example, and be consistent with the contract that follows.
The lender must explain the key features of the product and their specific effects on that customer, including the consequences of non-payment. It is an obligation separate from delivering the documents, and it must also be provable.
The contractual document has its own list of mandatory particulars, which partly overlaps with the pre-contractual form but does not match it. The customer must receive their copy at the time of signing.
The withdrawal period runs from signing, or from receipt of the contractual terms if that is later. From then on, periodic information obligations begin, and they are particularly demanding for revolving credit products.
Pre-contractual information defects have an awkward feature: they are systematic. If the documentation package is wrong, it is wrong in every contract signed with that template.
Loss of the agreed remuneration: omitting essential particulars from the contractual document can reduce the consumer’s obligation, leaving the credit without the expected remuneration or limiting it to the statutory interest rate.
Unenforceability of clauses that fail the incorporation test: what was not delivered in good time or in an understandable form can hardly be enforced against the consumer later.
Extension of the withdrawal period: if the mandatory information was not provided correctly, the calculation of the withdrawal period may be affected, prolonging uncertainty over transactions believed to be closed.
It is up to the lender to prove that it delivered the information and when. A system that records that it “was accepted” but not which document was made available does not serve that evidentiary purpose.
An advertisement, a form and a contract showing different figures is one of the easiest findings for a claimant to document, and one of the hardest for the lender to justify.
Regardless of the civil-law effect on the contract, transparency breaches have their own penalty regime and can be detected by sampling during a supervisory review.
We audit your full documentation package—advertising, pre-contractual form, explanations, contract and evidence of delivery—across every channel you sell through, and give you prioritized corrections.
SECCI stands for Standard European Consumer Credit Information. It is a document with a prescribed format and content that the lender must give the consumer before they are bound by the contract, so that they can compare offers from different lenders on an equal footing.
Its value is not only informational: in litigation, it is the piece of evidence that shows what the customer was told about the cost and terms before signing.
The content is standardized. The blocks that can never be missing are:
The law requires it to be delivered in good time before the consumer is bound, without setting a specific number of hours in every case. That open-ended wording is no advantage for the lender: it must justify, for each channel, that there was real time to read and compare.
In practice, the most problematic channel is the point of sale, where the information and the signature tend to happen in the same act. There, it is advisable to add a deliberate intermediate step and keep a record of it.
An instrument that allows the consumer to store information addressed personally to them, access it later and reproduce it unchanged. Paper qualifies; so does a PDF that can be downloaded or is sent by email.
What normally does not meet that requirement is a screen that the user sees and can no longer retrieve, or a link to a page that the lender can later change without leaving a trace of the previous version.
The consequence is not merely formal. Spanish consumer credit legislation provides that the omission of certain essential particulars from the contractual document affects the consumer’s obligation, which may be reduced to repaying the principal only or to paying statutory interest, depending on the case.
That is why the pre-contractual form and the contract should be treated as a single, consistent package: it is common to find lenders with a flawless form and a contract that is missing a mandatory particular, or the other way around.
With three elements that must be expressly designed, because no system stores them by default:
Without the third, you can prove that a document was delivered, but you cannot reconstruct exactly what it said or how it was presented.
Yes. The EU consumer credit reform updates the content and presentation of pre-contractual information, adds warnings about the cost of borrowing and pays specific attention to sign-up on small screens and to products that previously fell outside the scope of the rules.
For an established lender, the work consists of reviewing template by template and channel by channel, not redoing everything from scratch.
Pre-contractual documentation must meet three conditions to be defensible: say the same as the contract, be understandable to someone who does not work in banking, and leave a record that it was delivered. All three have to be designed; none of them appears on its own.
The figures in the advertisement, the pre-contractual form and the contractual document must match. Set up a single source of truth for the cost calculation and do not let each team produce its own examples.
The form is a standardized document, but that does not stop you from taking care over the wording you can control. Test the text with people outside the industry: if they cannot say how much they will pay in total, the document is not finished yet.
Store each template with its period of validity and link each contract to the specific version applied to it. This is what lets you reconstruct, five years later, exactly which document that customer had in front of them.
If you need to audit your pre-contractual documentation, explore our fintech regulation services or request a free consultation.
A correct form can fail because of where it is delivered, when it is delivered or what is recorded. These blocks walk through the pieces you need to have in place: content, timing, medium, proof and allocation of responsibilities.
1) ContentThe content is prescribed and cannot be cut for design reasons. Every omitted block is an argument available to anyone who brings a claim, and the most neglected blocks are always the same.
2) TimingSufficiently in advance of the customer being bound. In fast channels, this requires deliberately adding an intermediate step and recording that it took place.
3) MediumOn a durable medium: something the customer can store, retrieve and reproduce without alteration. A link to an editable page does not serve that purpose.
4) The deciding pieceEverything above is decided here. In proceedings, the lender must be able to produce the exact document generated for that customer, the date and time it was made available to them and the template version in force that day. Most systems store a flag showing that the step was completed, which proves none of the above. Reconstructing that traceability after the fact is impossible: either it was designed in from the start, or it does not exist.
Responsibility mapResponsible for the content, the timing and the proof of delivery, even if a third party physically carries it out on its behalf.
Must pass on the lender’s information and disclose its relationship with the lender and the commissions it receives.
Its staff are not financial advisers. The more they are asked to explain, the more exposed the lender that uses them becomes.
To allow offers from different lenders to be compared before deciding. Its format is standardized precisely for that reason.
To set out the rights and obligations of the parties. Its mandatory content is broader and not limited to cost.
Before the consumer is bound, sufficiently in advance to read it and compare.
At the time of contracting, with a copy given to the consumer immediately.
It weakens the incorporation and transparency review of the clauses and may affect the calculation of the withdrawal period.
The omission of essential particulars may reduce the consumer’s obligation under consumer credit legislation.
The lender, with the specific terms offered to that customer, even if an intermediary delivers it.
The lender, as the party that drafts the standard terms, which triggers the review of standard terms and conditions over its content.
The generated document, the timestamp and the template version. This is the most neglected piece.
The signed contract and evidence that a copy was delivered, which is usually better handled than the former.
None of these symptoms can be detected by looking at the template: they all appear when you try to reconstruct a specific case. That is why it is worth running the test before a court does.
Terms that appear in templates, in supervisory requests for information and in lawsuits. Getting product, technology and legal teams to use them the same way avoids half the defects.
A form with prescribed content and format that must be delivered before the consumer is bound, so that they can compare offers from different lenders on an equal footing.
An indicator that expresses the total cost of credit in annual terms, including interest, fees and other mandatory charges. It must match across advertising, the pre-contractual form and the contract.
An instrument that allows the consumer to store information addressed to them, access it later and reproduce it unchanged. Paper and PDF qualify; an ephemeral screen does not.
A sufficient time margin between delivery of the information and the moment the consumer is bound. It does not always translate into a number of hours, so it has to be justified channel by channel.
The obligation to explain to the consumer the key features of the product and its effects on their situation, including the consequences of non-payment. It comes in addition to delivering the documents.
A simulation with specific figures that must accompany advertising that mentions financial terms, giving the consumer a realistic idea of the cost of the advertised product.
Insurance or other services that must be taken out to obtain the credit on the terms offered. Their cost must be included in the total cost and stated in the form.
An examination of whether a pre-drafted clause validly became part of the contract: prior delivery, legibility and accessibility. It is distinct from, and comes before, the substantive transparency test.
Identification of which document template was in use on the date of each contract. Without it, you cannot reconstruct exactly what the customer read, however carefully the acknowledgment of receipt is kept.
REGULATORY CONTROL CENTER · PRE-CONTRACTUAL INFORMATION
The content of pre-contractual information is identical in every channel. What changes is the ability to prove delivery, timing and version. This dashboard summarizes where the process should be strengthened in each one.
An indicative guide for prioritizing the audit: which channel poses the greatest evidentiary difficulty for each requirement.
Tell us which channels you sell through and what documentation you deliver, and we will tell you which part of the package would withstand a claim alleging a lack of pre-contractual information.
The obligation to inform the consumer before they are bound by a credit agreement is probably the oldest and most litigated element of financial consumer law. In Spain, it rests on Law 16/2011 on Consumer Credit Agreements, which brought the EU model of the standardized information form and the duty to assist the consumer into Spanish law, and it is complemented by banking transparency rules and by the specific rules on distance contracting.
The Standard European Consumer Credit Information form was created with a specific goal: to let a consumer put two offers from two different lenders side by side and compare them without being an expert. That is why its structure, order and headings are set by law. Adapting the design “to make it look better” or removing blocks for space reasons is one of the most common temptations for product teams, and one of the easiest sources of defects for claimants to prove.
Alongside delivering the documents, there is a separate obligation: to provide adequate explanations so that the consumer can assess whether the contract suits their needs and financial situation. It is a conduct obligation, fulfilled in the conversation or in the sign-up flow, and it must also be provable. In assisted channels, this means a script and training; in digital channels, interface design decisions.
In our experience reviewing documentation packages, the content of the form is usually reasonably correct. What fails is the ability to prove, three or five years later, which specific document that customer saw, when and with which template version. Systems usually store a flag showing that the step was completed, which proves none of those three things. And that traceability cannot be reconstructed after the fact: either it was designed in from the start, or it simply does not exist.
The EU consumer credit reform updates the content and presentation of pre-contractual information, strengthens the warnings about the cost of borrowing, expressly addresses sign-up on small-screen devices and extends the scope to products that were previously excluded. For an established lender, the work does not consist of redoing everything, but of reviewing template by template, channel by channel, and of using the review to solve the traceability problem that was almost always there.
Key legislation, linked to the official text:
Legislation and links reviewed in .