FFFS 2018:16 Amendments: The Consumer Carve-Out From 20 November 2026

On 13 October 2026 Finansinspektionen (FI) decided FFFS 2026:34, a consequential amendment to its credit-risk regulations FFFS 2018:16, effective 20 November 2026. The amendment rewrites 1 kap. 3 §: the housing-credit reference moves from 2 § of the Consumer Credit Act (2010:1846) to 1 kap. 3 § of the Consumer Credit Act (2026:1011). The instrument contains that one provision and its entry-into-force line, with no transitional provision. It is the second of two FFFS 2018:16 amendments this year: FFFS 2026:19 already changed the board’s review cycle for credit delegation rules and the related-party circle from 1 July 2026.

The provision being rewritten decides which loans fall under Chapter 4 (credit assessment, kreditprövning) and Chapter 5 (credit decisions, kreditbeslut). FI treats the change as a pure consequential amendment, made so that the reference stays correct once the new consumer credit legislation applies. For institutions, the work lands in the internal rules, credit manuals and product flags that still name the 2010 Act as the test for whether a consumer loan runs through the Chapter 4 and 5 workflow.

Related reading: Swedish Bank Capital Requirements: FI Moves Model Add-Ons to Pillar 1

The 2026 FFFS 2018:16 amendments at a glance

Two instruments amend FFFS 2018:16 in 2026, and FI’s register lists no other amendment since the regulations took effect on 1 March 2019. The dates below come from FI’s announcement, its regulatory register and the instruments’ decision materials.

FFFS 2026:34 amends only 1 kap. 3 § and introduces no regulatory return. It contains no transitional provision and takes effect on 20 November 2026. Its preamble cites 5 kap. 2 § points 5, 13 and 14 of the Banking and Financing Business Ordinance (2004:329) and 6 kap. 1 § point 9 of the Securities Market Ordinance (2007:572) as enabling provisions.

The same 13 October decision covers sister instruments that also enter into force on 20 November 2026: FFFS 2026:33 amends FFFS 2015:1 on interest-rate information for housing credit, FFFS 2026:35 amends FFFS 2023:12 on owner and management assessment, and FI issues new general guidelines on consumer credit and new regulations on housing credit and certain other consumer credit.

What FFFS 2026:34 changes in 1 kap. 3 §

The section keeps its structure. Only the statutory reference at its end changes.

FI’s decision memorandum of 13 October 2026 (FI dnr 26-1152) explains the amendments. Section 2 identifies changes to FFFS 2018:16 and FFFS 2015:1 as purely consequential and does not discuss them separately. The triggers are the widening and renaming of the Housing Credit Business Act (2016:1024) so that it also covers certain other consumer credit, the new Consumer Credit Act, and FI’s new general guidelines on credit in consumer relationships. Section 1.1 adds that the changes are made so that references in the regulations remain correct after the legislative changes.

One drafting detail matters for anyone mapping systems to the rule. FFFS 2018:16 never defines housing credit itself. Its own definitions in 1 kap. 5 § cover terms such as credit, credit decision and credit process, and its definition of credit is deliberately wide: an agreement, other legal relationship or limit that gives the firm, or can give it, a claim on a counterparty. The housing-credit test is imported wholesale from consumer credit law, so when the law changes, the test changes with it unless FI re-points the reference. That is the re-pointing FFFS 2026:34 makes, and FI describes it as a consequential amendment.

Which loans Chapters 4 and 5 still reach

Chapters 4 and 5 are the operational core of the regulations. Chapter 4 requires credit assessment on well-defined criteria, an investigation of whether connected clients need a group limit (samlimitering), assessment of any guarantor, a forward-looking analysis grounded in available history, a sensitivity analysis of repayment capacity and collateral value for exposures to institutions and companies, and a test of repayment capacity on assumptions of adverse exchange-rate movements when credit is granted in a currency other than the borrower’s main earnings currency and the borrower lacks a natural currency hedge. Chapter 5 requires decision-makers with enough experience for the size, risk and terms of the credit, decisions taken within the internal rules and a sound risk culture, a decision basis that shows how Chapter 4 was met, and documentation of who decided, on what terms and why.

After 20 November 2026 the split of a credit institution’s book looks like this:

The carve-out is narrower than it looks. 1 kap. 3 § switches off two chapters, and only two. A bank’s consumer lending outside housing credit still sits inside Chapter 2 (risk appetite with limits, risk strategy, and internal rules that must cover decision mandates, collateral principles, decision basis and documentation requirements), Chapter 3 (identification and measurement, including impairments, reversals and write-offs), Chapter 6 (review of all credits at least once a year, with individual review where the internal rules require it given size and risk), Chapter 7 (credits with increased risk) and Chapter 8 (credits to the related-party circle).

The documentation point needs separate mapping. FFFS 2018:16 defines a credit decision to include decisions on individually assessed impairments, their reversal and write-offs. For consumer credit that is not housing credit, the Chapter 5 documentation duty therefore does not apply to those decisions. 2 kap. 3 § point 9 still requires the internal rules to set documentation requirements for the handling of credit cases, including the decision basis and the credit decision, and that requirement has no consumer carve-out. Separately, 4 kap. 6 § of FFFS 2026:31 requires documentation of credit-case handling, the decision basis, the credit assessment and the information gathered. Under 1 kap. 6 § of FFFS 2026:31, that provision applies to credit institutions for their consumer lending other than housing credit, from 20 November 2026.

Reading the new housing-credit definition against the old one

From 20 November 2026, FFFS 2026:34 refers the housing-credit scope test to 1 kap. 3 § of the Consumer Credit Act (2026:1011). Its housing-credit definition has two limbs. The first covers credit secured by a mortgage over real property, a site-leasehold (tomträtt) or a tenant-owner right (bostadsrätt) or a similar right, or a corresponding right in a building that does not belong to the property. The second covers credit taken to acquire or keep ownership of such property, unless it is temporary financing during a transition to another financing arrangement and the credit either has no fixed term or must be repaid within 12 months.

Section 2 of the 2010 Act, due to be repealed on 20 November 2026, contains the same two limbs and bridging exception, including the 12-month limit. On their face, the definitions match, which fits FI’s own description of FFFS 2026:34 as a consequential amendment. FI does not discuss the comparison in the memo, so that conclusion is an interpretation, and it is the first thing a legal review of the change should confirm.

The definition turns on security or purpose. Product names play no part, so a classification built on product labels can drift away from the legal test:

• A consumer loan secured by a pledge over a tenant-owner apartment falls within the first limb even if it finances a car, so Chapters 4 and 5 apply.
• An unsecured consumer loan taken to buy a home falls within the second limb by purpose, unless the bridging exception catches it.
• A bridging loan may fall outside the purpose-based limb of the housing-credit definition where it provides temporary finance during a transition to another financing arrangement and has no fixed term or is repayable within 12 months. The exception does not override the separate security-based limb. If the bridging loan is secured by qualifying residential property or housing rights, Chapters 4 and 5 still apply.

The consumer side of the test also comes from the Act. A consumer is a natural person acting mainly for purposes outside business activity. A sole trader borrowing mainly for the business is therefore a non-consumer borrower for this test, and Chapters 4 and 5 apply whatever the security.

Investment firms: why the change barely reaches them

The title of FFFS 2018:16 names both credit institutions and investment firms, and the scope list in 1 kap. 1 § includes investment firms (värdepappersbolag). 1 kap. 2 § then narrows their obligations to three provisions: 3 kap. 1 § first paragraph point 7, 3 kap. 1 § second paragraph and 3 kap. 2 § first paragraph. Those cover systems for the firm’s total credit risk, their proportionate design, and processes for measuring the level of credit risk.

Chapters 4 and 5 were never among them. A carve-out from chapters that do not apply changes nothing for a stand-alone investment firm, and neither do the July 2026 changes to Chapters 2 and 8. On the scope provisions, an investment firm’s compliance map for FFFS 2018:16 is unchanged by both 2026 amendments.

The exception sits inside the banks. 1 kap. 1 § second paragraph applies the regulations and general guidelines to the securities business carried on within banks, savings banks, member banks, credit market companies and credit market associations. Lending in a bank’s securities business follows the same 1 kap. 3 § split as the rest of its book.

Where other consumer credit sits from 20 November 2026

For credit institutions, the 2018 structure stays as it was, and the consumer framework around it is rebuilt. FI’s decision memorandum of 13 October 2026 describes the new Consumer Credit Act as bringing interest-free and fee-free consumer credit into scope in more cases, always covering third-party credit for purchases of goods and services, and tightening the creditworthiness provisions. Under 3 kap. 13 § of the new Act, the trader must assess whether the consumer has the financial means to meet the commitments under the credit agreement.

For housing credit the Act applies that same test, plus 3 kap. 14 to 16 §§, through 8 kap. 13 §. A consumer housing loan in a Swedish bank therefore runs two tests side by side: the Act’s consumer creditworthiness assessment and the prudential credit assessment in Chapter 4 of FFFS 2018:16. They answer different questions, and one does not discharge the other.

FI’s regulatory package decided on 13 October 2026 includes the following consumer-credit instruments:

• FFFS 2026:32, the new general guidelines on credit in consumer relationships, replaces FFFS 2025:10 from 20 November 2026. FI describes the previous guidance as largely unchanged in substance, apart from certain linguistic adjustments, while clarifying the information lenders should use and check in creditworthiness assessments. As general guidelines, these provisions are recommendations rather than binding regulations.
• New regulations and general guidelines on housing credit and certain other consumer credit, replacing FFFS 2016:29. According to the memo, the new internal-rule provisions apply to credit institutions only for the part of their business concerning consumer credit other than housing credit, alongside the general governance rules in FFFS 2014:1.
• A consequential change to FFFS 2015:1 through FFFS 2026:33, and an amendment to FFFS 2023:12 through FFFS 2026:35 that brings Swedish firms under FI supervision that grant consumer credit other than housing credit within the owner and management assessment rules.

Under 4 kap. 20 § of FFFS 2026:31, a firm lending consumer credit other than housing credit must have internal rules for credit granting that set out the full creditworthiness routine, which information on the consumer is collected and from which sources, the conditions for granting, accepted collateral, limits, decision levels, which credits are reported to the board, and routines for reporting credit risk and credit exposure. Under 4 kap. 2 § the board must adopt them, and they must be evaluated regularly, at least every second year, and updated where needed. FI’s decision memorandum of 13 October 2026 links automated decision support to dual control, and the general guidelines attached to 4 kap. 20 § of FFFS 2026:31 recommend that no individual handle a credit case throughout the credit-granting process. They address automated systems separately: they recommend specifying in internal rules how automated decision systems and other technical systems are continuously checked for compliance with legal and internal credit-granting requirements. As general guidelines, these are recommendations.

This advice mirrors point 6 of the general guidelines on risk culture in 2 kap. 4 § of FFFS 2018:16, which already recommends that no individual handle a credit case throughout the entire lending process. FFFS 2026:31 carries comparable guidance for non-housing consumer credit from 20 November 2026. Both provisions are framed as recommendations.

FI’s decision memorandum of 13 October 2026 (section 2.1) notes that Konsumentverket will issue new general guidelines on certain provisions of the new Consumer Credit Act, including marketing and contract terms, proposed to take effect on 20 November 2026, and that Konsumentverket’s regulation will apply in full to firms under FI supervision. Separately, Konsumentverket published binding regulations KOVFS 2026:1 on 5 October 2026 on staff competence and acting in the consumer’s interests, for credit providers and intermediaries that fall under its supervision rather than FI’s. Konsumentverket’s own Q&A states that FI’s regulations and general guidelines apply to firms under FI supervision, so KOVFS 2026:1 and FI’s rules cover different populations.

FFFS 2026:19: a two-year review cycle and a renamed control-function list

The first 2026 amendment came out of a different package. FFFS 2026:19 was decided on 16 June 2026 with FI’s implementation of the CRD changes made by Directive (EU) 2024/1619, and it rewrote two sections of FFFS 2018:16 from 1 July 2026.

2 kap. 5 §: delegation rules for credit decisions

The board must now evaluate and confirm that the firm’s delegation rules for credit decisions are appropriate at least every second year. The base text required this annually. FI’s memo ties the change to the new wording of 6 kap. 5 § of the Banking and Financing Business Act (2004:297), under which internal guidelines and instructions are evaluated and reviewed at least every second year, and FI made the same change to the review provisions in FFFS 2014:1 and FFFS 2010:7.

The two-year figure is a maximum interval between reviews. FI states that the board must review the documents at least every second year in all circumstances, that a credit institution must meet the requirements on its business at all times, and that a need for review can arise at any moment. FI expects the practical effect to be limited. On that reasoning, a change such as a reorganised credit committee or a new lending segment can bring a review forward before the two years are up.

8 kap. 2 §: who counts as a person in a leading position

Chapter 8 supplements 8 kap. 5 and 6 §§ of the Banking and Financing Business Act on services to the related-party circle (jävskrets). 8 kap. 2 § lists the persons who at least count as holding a leading position. FFFS 2026:19 replaced “the firm’s chief risk officer and the heads of the other independent control functions” with “the firm’s heads of the independent control functions”, and updated the executive-management limb to refer to 1 kap. 4 § point 7 of FFFS 2011:1 on remuneration systems in credit institutions (previously point 8).

FI explains the first change as consequential: it repealed the chief risk officer provisions in 7 kap. 4 to 6 §§ of FFFS 2014:1, taking the view that the CRD amendments require the risk control function always to have a head. The person leading risk control stays inside the related-party circle, now as the head of an independent control function. The contents of the related-party credit list in 8 kap. 5 § did not change.

The same June memo, FI dnr 25-9724, carried FI’s new rules for third-country branches, which mainly enter into force on 11 January 2027, covered in our CRD6 third-country branch authorisation guide.

Three internal documents to re-point

FFFS 2018:16 governs how a Swedish institution assesses, decides and reviews credit, and neither 2026 amendment touches a reporting regulation. How much it lends, and how the exposures appear in supervisory data, runs through other instruments: the FINREP breakdowns discussed in our FI Bank Barometer H2 2025 credit risk reporting analysis, and FI’s national balance-sheet and income-statement return under FFFS 2014:14, explained in our Standardrapport (STND) reporting guide.

The amendments still leave paper trails inside the firm:

• Internal rules under 2 kap. 3 § that quote 2 § of the 2010 Act as the housing-credit test will cite a repealed provision from 20 November 2026.
• Credit-system logic that routes consumer applications into the Chapter 4 and 5 workflow encodes the same definition, and its rule text or documentation may cite the 2010 Act as well.
• The board’s calendar for reviewing delegation rules, and the list of people captured by the related-party circle, follow the July 2026 wording of 2 kap. 5 § and 8 kap. 2 §.

Legacy contracts raise one open question. Under the transitional provisions of the 2026 Act, the 2010 Act continues to govern credit agreements concluded before 20 November 2026, with listed exceptions for open-ended agreements. FFFS 2026:34 takes effect on that date and contains no transitional provision, so the Chapters 4 and 5 scope test refers to the 2026 Act’s housing-credit definition from 20 November 2026. Neither the instrument nor FI’s decision memorandum addresses how that reference operates for loans under agreements the 2010 Act still governs, so any conclusion on existing loans is an interpretation.

Frequently Asked Questions

Does a consumer loan granted before 20 November 2026 need to be re-assessed under Chapter 4 because of FFFS 2026:34?

FFFS 2026:34 only re-points the scope reference in 1 kap. 3 § and contains no transitional provision or reassessment requirement. Independently, Chapter 6 of FFFS 2018:16 already requires review of all credits at least annually, with more frequent review for higher-risk credits.

A customer refinances a car loan and secures it with a pledge over their tenant-owner apartment. Does the new loan fall under Chapters 4 and 5?

Yes, on the text of the definition. Credit secured by a pledge over a tenant-owner right is housing credit under the first limb of 1 kap. 3 § of the 2026 Act, whatever it finances, so the credit assessment and decision rules in Chapters 4 and 5 apply to the refinanced loan.

Which side of the line is a loan to a sole trader that is used partly for household costs?

The Act defines a consumer as a natural person acting mainly for purposes outside business activity. The test is the main purpose. A loan used mainly for the business is a non-consumer credit and falls under Chapters 4 and 5; one used mainly for private purposes is consumer credit, and Chapters 4 and 5 then apply only if it is also housing credit. The classification therefore rests on what the credit file shows about the main use of funds.

Is the 12-month bridging loan exception new?

No. Section 2 of the 2010 Act contains the same exception for temporary financing during a transition to another financing arrangement, where the credit has no fixed term or must be repaid within 12 months. The exception remains in force until 19 November 2026 and is carried forward under the new Act from 20 November 2026, within the purpose-based limb of the housing-credit definition. A bridging loan secured by qualifying property or housing rights remains housing credit under the separate security-based limb and is subject to Chapters 4 and 5.

Our board approved the credit delegation rules in March 2026 under the old annual rule. When is the next evaluation due?

Since 1 July 2026, 2 kap. 5 § requires evaluation at least every second year, so the outer limit is two years after the March 2026 evaluation. FI’s memo adds that a need for review can arise at any time, so a change to the credit organisation or mandates can bring it forward.

A consumer takes a housing loan in euros while earning a salary in kronor. Does the foreign-currency test in Chapter 4 apply?

Chapter 4 applies to consumer housing credit. Under 4 kap. 6 § of FFFS 2018:16, the adverse-exchange-rate assessment is required where the credit currency differs from the borrower’s main earnings currency and the borrower lacks a natural currency hedge. The accompanying general guidelines recommend providing adequate information about the risks. Whether the loan also qualifies as foreign-currency housing credit under 1 kap. 3 § of the 2026 Consumer Credit Act depends on the currencies of the consumer’s EEA country of residence, income and assets intended for repayment. Earning a salary in kronor does not establish that classification by itself.

Related Articles

• Swedish Bank Capital Requirements: FI Moves Model Add-Ons to Pillar 1: FI’s move of model add-ons into Pillar 1 for Swedish banks.
• Standardrapport (STND) Reporting in Sweden: The Quarterly FI Filing: who files FI’s national balance-sheet return under FFFS 2014:14, when, and through Fidac.
• FI Bank Barometer H2 2025: What the Lending Slowdown Means for EU Credit Risk Reporting: FI’s H2 2025 lending data and the FINREP breakdowns that capture it.
• CRD6 Third-Country Branch Authorisation: The 11 January 2027 Deadline: the CRD VI branch regime that FI implemented in the same June 2026 package as FFFS 2026:19.
• Swedish Countercyclical Capital Buffer: Riksbank Holds at 2%: the Riksbank’s decision to hold the Swedish countercyclical buffer rate at 2%.

Key Takeaways

• Scope from 20 November 2026: non-consumer credit and consumer housing credit go through Chapters 4 and 5 of FFFS 2018:16; all other consumer credit stays outside those two chapters.
• A routing flag set from collateral type alone misses consumer loans taken to buy or keep a home without security, which are housing credit by purpose.
• Individual impairment and write-off decisions on consumer credit that is not housing credit fall outside the Chapter 5 documentation duty but inside the documentation rules that 2 kap. 3 § point 9 requires the internal rules to set.
• Stand-alone investment firms: neither 2026 amendment alters the three Chapter 3 provisions that 1 kap. 2 § applies to them.
• Related-party lending: the leading-position list in 8 kap. 2 § reads heads of the independent control functions since 1 July 2026, which keeps the head of risk control inside the circle.
• Legacy consumer contracts: the 2010 Act will continue to govern agreements concluded before 20 November 2026, subject to statutory exceptions. FFFS 2026:34 refers the prudential scope test to the new housing-credit definition and contains no transitional provision.

Sources and References

• Finansinspektionen, FFFS 2026:34, amending FFFS 2018:16 (decided 13 October 2026, in force 20 November 2026): https://www.fi.se/contentassets/b73c129c1305464a9ea9532d81ae5e03/fs2634.pdf
• Finansinspektionen, register entry for FFFS 2026:34: https://www.fi.se/sv/vara-register/fffs/sok-fffs/2018/201816/202634/
• Finansinspektionen, Beslutspromemoria “Nya föreskrifter och allmänna råd om konsumentkrediter”, FI dnr 26-1152 (13 October 2026): https://www.fi.se/contentassets/b73c129c1305464a9ea9532d81ae5e03/beslutspromemoria-nya-foreskrifter-och-allmanna-rad-om-konsumentkrediter.pdf
• Finansinspektionen, FFFS 2018:16, regulations and general guidelines on credit risk management in credit institutions and investment firms (decided 18 September 2018, in force 1 March 2019): https://www.fi.se/contentassets/2b00a4a8f3834fdb9a4be132d564add1/fs1816.pdf
• Finansinspektionen, register entry for FFFS 2018:16 and its amendments: https://www.fi.se/sv/vara-register/fffs/sok-fffs/2018/201816/
• Finansinspektionen, FFFS 2026:19, amending FFFS 2018:16 (decided 16 June 2026, in force 1 July 2026): https://www.fi.se/contentassets/de56928ebce84ace84047835fb72ac2f/fs2619.pdf
• Finansinspektionen, Beslutspromemoria “Ändrade föreskrifter med anledning av ändringar i bland annat kapitaltäckningsdirektivet”, FI dnr 25-9724 (16 June 2026): https://www.fi.se/globalassets/media/dokument/fffs-bilagor/2026/beslutspm-fffs-2026-9-22.pdf
• Finansinspektionen, list of FFFS instruments (FFFS 2026:33 and FFFS 2026:35): https://www.fi.se/sv/vara-register/fffs/forteckning-fffs/
• Konsumentkreditlag (2026:1011), Sveriges riksdag: https://data.riksdagen.se/dokument/sfs-2026-1011.html
• Konsumentkreditlag (2010:1846), Sveriges riksdag (repealed from 20 November 2026): https://data.riksdagen.se/dokument/sfs-2010-1846.text
• Finansinspektionen, FFFS 2026:31, regulations and general guidelines on housing credit and certain other consumer credit (decided 13 October 2026, in force 20 November 2026): https://www.fi.se/contentassets/a68a09ad9a074ede81a5483e6e759999/fs2631.pdf
• Finansinspektionen, register entry for FFFS 2026:32, general guidelines on credit in consumer relationships: https://www.fi.se/sv/vara-register/fffs/sok-fffs/2026/202632/
• Konsumentverket, news item on new regulations for consumer credit (5 October 2026, KOVFS 2026:1): https://www.konsumentverket.se/nyhet/nya-foreskrifter-tydliggor-foretagens-ansvar-for-konsumentkrediter/
• Konsumentverket, questions and answers on the new rules for certain consumer credit: https://www.konsumentverket.se/marknadsratt-foretag/fragor-och-svar-angaende-nya-regler-for-vissa-konsumentkrediter/
• Directive (EU) 2023/2225 of 18 October 2023 on credit agreements for consumers and repealing Directive 2008/48/EC: https://eur-lex.europa.eu/eli/dir/2023/2225/oj
• Directive (EU) 2024/1619 amending Directive 2013/36/EU (CRD VI): https://eur-lex.europa.eu/eli/dir/2024/1619/oj
• Finansinspektionen, FFFS 2014:14 on reporting of quarterly and annual accounts data (Standardrapport): https://www.fi.se/sv/vara-register/fffs/sok-fffs/2014/201414/

Before the 20 November 2026 switch-over

Just over five weeks separate FI’s decision from entry into force. In that window, the internal rules adopted under 2 kap. 3 § need the new statutory reference, and the routing logic for consumer applications needs testing against both limbs of the housing-credit definition and the 12-month bridging exception. FFFS 2026:34 is a consequential amendment of the statutory reference and sets no date for re-adopting internal rules. Institutions that quote the 2010 Act should update the obsolete reference and keep evidence of testing any affected credit-classification controls. Governance duties under FI’s new consumer-credit regulations need to be assessed on their own terms.

Disclaimer: The information on RegReportingDesk.com is for educational and informational purposes only. It does not constitute legal, regulatory, tax, or compliance advice. Always consult your compliance officer, legal counsel, or the relevant supervisory authority for guidance specific to your institution.