Institutional and Legal Framework of Digital Fintech Credit Markets: Regulatory Solutions for Ukraine (Baltic Journal of Economic Studies)

Summary

• Directive (EU) 2023/2225 of 18 October 2023 expands European Union consumer credit regulations to cover loans under €200 which were previously excluded.p.4
• EU CCD2 guidelines mandate borrower creditworthiness assessments for small loans ranging from €200–500 using documented income via open banking APIs.p.4
• In Ukraine, Resolution No. 39 of the National Bank of Ukraine established the regulatory platform for testing innovative financial services.p.6
• The National Bank of Ukraine adopted the Strategy for the Development of Fintech in Ukraine until 2025 to guide digital finance integration.p.6
• United States digital lending governance includes state-level regulators such as California's DFPI and New York's NYDFS that oversee licensing and interest rates.p.3

Key insights

1. Global credit market supervision is transitioning from traditional institution-based models to function-based regulatory approaches.p.1
2. Online lending platforms in the United States combine federally regulated bank partnerships with multistate licensing to manage regulatory fragmentation.p.3
3. European Union rules under CCD2 require algorithm explainability, human intervention rights, and strict prohibitions on using sensitive data in credit scoring.p.4
4. Ukrainian financial regulation remains concentrated on traditional credit institutions rather than holistic digital credit ecosystems.p.6
5. Ukraine faces four key regulatory gaps including unclassified digital credit services, unstandardized alternative data usage, and missing AI credit scoring rules.p.8
6. Separating the digital fintech credit market as an independent supervisory object in Ukraine is recommended to enhance market stability and consumer protection.p.8