This is the author accepted manuscript. The final version is available from Kluwer Law InternationalDirective 2008/48/EC aims to guarantee a high level of consumer protection and comparability of
consumer credit offers, protecting consumers against over-indebtedness. In light of the ongoing
review of this directive, it is important to consider whether the principle of transparency could not
play a bigger role in ensuring that consumers are provided with understandable consumer credit
information. The authors argue, therefore, that the assessment of the credit information’s
transparency should go beyond a mere compliance check with formal aspects of transparency, i.e.
whether consumers had access to the information and whether it was legible. At least an equal
amount of consideration should be paid to aspects of the substantive transparency, i.e. whether
consumers ultimately understood the information. Moreover, the European Commission should
strengthen the consumer credit transparency toolbox by explaining the meaning and significance of
various transparency requirements, and re-check the effectiveness of the standardised credit
information.NWO - Netherlands Organisation for Scientific Researc
