Reed Smith In-depth

Key takeaways

  • The Directive imposes obligations on EU banks selling non-performing loans, non-bank purchasers of EU non-performing loans and non-performing loan servicers.
  • The European Commission has published the Implementing Technical Standards report, specifying disclosure templates for use by EU banks selling non-performing loans under the Directive.
  • Most member states are yet to bring the Directive into effect, despite the 30 December 2023 deadline for Member States to apply measures implementing the Directive.

Authors: Sarah Caldwell Ella Evagora Oliver Hogg, Angelina Shum

The non-performing loan (NPL) market has a significant presence in the European financial markets, valued at around €27.4 billion. EU Directive 2021/2167 on NPLs (the Directive) sets out new rules for credit servicers and credit purchasers aimed at promoting the secondary market for NPLs.


  • 28 December 2021 – effective date of the Directive
  • 29 December 2023 – deadline for the European Commission (EC) to produce a report on the review of the Directive
  • 30 December 2023 – deadline for member states to apply measures implementing the Directive
  • 29 June 2024 – deadline for credit servicers carrying on credit servicing activities on 30 December 2023 to obtain authorisation under the Directive