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Non-Bank Digital Lending in Europe: Why Weak Data and Manual Processes Increase Risk

Published on Dec 5, 2025
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Non-bank digital lending in Europe is growing rapidly. Yet despite this growth, many loan portfolios are still managed using Excel spreadsheets, PDFs, and long email threads. This creates a structural risk that is often underestimated, especially when institutional investors and lenders are managing portfolios worth millions of euros.

From a risk management perspective, the key question is simple. Can manual tools still provide sufficient transparency, control, and auditability in today’s non-bank lending market?

Podcast Insight: Nicolas Kipp on Risk, Regulation, and Infrastructure

In episode 22 of the podcast What’s Up Digital Lending, Constantin Fabricius from the Digital Lending Association spoke with Nicolas Kipp, Founder and CEO of Credibur, about current fault lines in the European non-bank lending ecosystem.

The conversation focused on three themes that are increasingly relevant for lenders, investors, and servicers.

CCD2 and the Pressure on BNPL Providers

One topic was the impact of the new Consumer Credit Directive 2 (CCD2) on consumer and BNPL lenders in Europe. CCD2 significantly expands regulatory scope, disclosure requirements, and consumer protection obligations.

Public statements from regulators and industry bodies indicate that many BNPL providers are reallocating resources away from growth toward compliance and cost control. While comprehensive performance data is still emerging, the regulatory tightening itself is well documented by the European Commission and national supervisors.

Source: European Commission, Consumer Credit Directive (EU) 2023/2225

Trade Finance Defaults and the Cost of Poor Data

The discussion also referenced recent trade finance defaults and what they reveal about data quality and covenant monitoring. In several high-profile cases, delayed reporting, fragmented data sources, and insufficient monitoring limited early detection of problems.

This aligns with a broader body of financial risk research. Supervisory institutions such as the BIS and ECB have repeatedly highlighted that weak data infrastructure undermines early warning systems and increases both operational and credit risk.

Source: Bank for International Settlements, Principles for effective risk data aggregation and risk reporting (BCBS 239)

Why Credibur Was Built: Bank-Grade Infrastructure for Non-Bank Lending

The final part of the conversation focused on why Credibur was built. According to Nicolas Kipp, the goal was intentionally pragmatic rather than flashy.

Credibur was designed as bank-grade software for non-bank lenders and investors. Its purpose is to replace fragmented spreadsheets and email-based workflows with structured data, continuous monitoring, and auditable processes across loan portfolios.

There is broad scientific and regulatory consensus that technology alone does not eliminate risk. However, structured data models, automated controls, and consistent reporting materially improve transparency, governance, and decision quality when implemented correctly.

Listen to the Full Episode.