CCD2 and KYC: How Compliance Is Reshaping Financial Services Across BENELUX
Regulatory pressure, cost efficiency, and rising expectations around customer care are changing the BENELUX financial sector. Aryza’s Eric Abcouwer, Director New Business Development with a background in core banking and enterprise software, shares where institutions feel the most pressure today, what drives buying decisions, and how the market is likely to evolve.
Where do BENELUX financial institutions feel the most pressure to adapt today?
Eric Abcouwer Financial institutions are under pressure from two directions. Regulation is the most visible driver, particularly KYC/AML and the Consumer Credit Directive II. At the same time, cost-income ratios continue to force banks and lenders to digitise processes and operate more efficiently. These pressures reinforce each other and leave little room for incremental change.
This is exactly where Aryza operates as a de facto end-to-end provider across the Lending and Collections lifecycle, with GRC capabilities including AML/KYC, Risk and Compliance embedded throughout the process rather than treated as isolated functions.
What does CCD2 change in practice for lenders and credit providers?
Eric Abcouwer CCD2 significantly expands the duty of care. Institutions must collect more data, assess affordability more thoroughly and actively determine whether customers are able to repay a loan. Importantly, it also requires early identification of financial distress, shifting responsibility further upstream into onboarding, credit decisioning and customer monitoring.
How do CCD2 timelines influence what institutions are doing right now?
Eric Abcouwer Requirements such as CCD2 are tied to concrete timelines. With national implementation required by November 2025 and application from November 2026, institutions know that preparation cannot be postponed. As a result, most institutions spent 2024 and 2025 redesigning processes, closing data gaps and introducing automation in preparation for enforcement. Now, in 2026, the focus has shifted to operating these new processes reliably at scale, embedding them into day-to-day decision-making and ensuring they hold up under supervisory scrutiny.
How is this regulatory shift affecting collections and receivables management?
Eric Abcouwer While there is a visible cost-of-living crisis across the BENELUX region, its impact is uneven, and a significant share of financial distress remains hidden. This translates into growing arrears across sectors. At the same time, collections activity is becoming more concentrated, with fewer but larger organisations processing increasing case volumes. This creates strong demand for automated, scalable and socially responsible collections processes.
How should institutions interpret the cost-of-living discussion in BENELUX when assessing customer risk and vulnerability?
Eric Abcouwer Energy, food and housing costs remain structurally higher than before the pandemic, continuing to affect household affordability even as headline inflation moderates. The impact differs by country and customer segment. In Belgium, automatic wage indexation partially offsets inflation for many employees, while in the Netherlands and Luxembourg income growth is less systematically linked to rising prices. As a result, financial stress is concentrated in specific groups, including low-income households, renters and customers whose incomes do not keep pace with sustained cost levels. For financial institutions, this means vulnerability cannot be assessed purely at a macro level and requires early, data-driven identification at the individual customer level.
Which types of institutions and use cases are most affected today?
Eric Abcouwer KYC and onboarding affect a broad range of organisations, including banks, insurers, fund managers and lenders. In fund management, for example, both investors and investment targets must be screened. Institutions are under pressure to manage these checks consistently across jurisdictions while reducing onboarding times, accelerating time-to-revenue and controlling costs over the customer lifecycle – an area addressed by solutions such as Aryza Validate.
Collections and receivables management primarily affect organisations with high volumes, such as self-collecting companies and larger debt collection agencies. Here, automation is essential to handle scale while maintaining consistency and fair treatment.
Why do existing core banking systems struggle to support these changes?
Eric Abcouwer Core banking systems are reliable but inherently rigid. They were not designed for frequent regulatory change, rapid product launches or flexible customer interaction. Replacing them is risky, expensive and often postponed, which limits how quickly institutions can adapt to new requirements like CCD2.
How do banks overcome these limitations in practice?
Eric Abcouwer Most banks have invested heavily in building API layers around their core systems. These layers make the core accessible and allow external platforms to connect and exchange data. Combined with no-code and low-code approaches, this enables business teams to adapt processes and launch changes without large IT projects, while leaving the core untouched.
How isConversational AI changing customer conversations?
Eric Abcouwer Conversational AI is increasingly used across the customer lifecycle, extending beyond collections into onboarding, servicing and customer engagement, shaping how organisations are perceived in customer interactions. Blended models now combine AI-driven and live agent conversations across digital channels, including voice. This enables contact centres to handle high volumes more efficiently, improve conversation outcomes, reduce operational costs and retain human intervention where needed.
Looking ahead, what will change most in the BENELUX market?
Eric Abcouwer Automation and AI will become deeply embedded across compliance, KYC and collections. Hidden financial distress and arrears are expected to increase, reinforcing the need for early detection and socially responsible handling at scale. Rather than replacing core systems, institutions will continue to rely on modular, focused solutions layered on top.