• 34 ACCIS members responded to the survey, representing 27 European countries, providing strong coverage of the European credit reporting landscape.
• There are large differences among CRAs in terms of business models. The large majority operate as for-profit organisations (85%), while a minority are not-for-profit (located in Albania, Belgium, Czech Republic, Kosovo and the Netherlands).
• Ownership forms vary widely: 32% of CRAs operate as a subsidiary, 21% as a commercial listed company, 12% as public/government, 6% are owned by a lenders’ association, and 29% fall under other forms (foundations, bank-owned companies, associations, non-listed stock corporations).
• CRAs range from very young agencies (the youngest has been operating for 7 years) to long-established players dating back to the end of the 19th century.
• The scope of borrowers covered varies by country: in 11 of 27 countries, CRAs collect data on all types of entities, while in others (e.g. Belgium, Romania, the Netherlands) the scope is much more limited.

CRAs primarily hold and collect information on consumer loans (91%), credit and store cards (88%), mortgages (88%), credit lines on current accounts (85%) and leasing (85%). For the first time, the survey also captured Buy Now Pay Later (BNPL) data, which is held by 47% of CRAs, reflecting the growing relevance of this product. Consistent with previous surveys, the depth of data on mainstream lending products remains the highest, for both positive and negative records, with banking products and leasing showing the greatest granularity. The most common data retention period is 37–60 months for both general retention and personalised data after accounts are closed. Credit reports, credit scores, identity checking and portfolio monitoring are the most frequently used services by CRA clients, followed by fraud prevention and detection, risk analytics and benchmarking. Banks remain the dominant counterparty (94%), followed by leasing companies, credit card suppliers, micro-credit institutions and retail credit suppliers. CRAs maintain strong data quality frameworks: 97% apply clearly defined validation controls and data input requirements, 94% incorporate consumer complaints into quality management, and 91% perform checks each time data is received. Nearly 75% comply with formal standards (ISO 27001 being the most common), and 56% undergo independent external audits. AI adoption remains at an early stage, with around 24% of CRAs using AI in scoring models and 38% in internal processes. More than half of CRAs provide educational materials to help borrowers improve their financial health.

More than half of CRAs reported that there is no legal obligation for lenders to consult them, a share that has remained largely unchanged since 2020. A majority of CRAs (71%) reported that access to public/court data is permitted by regulation, whereas only 26% indicated that such access is required by national legislation. About half of CRAs are subject to specific legal or regulatory schemes for entering the market, and 44% reported other specific provisions governing their activities. CRAs process data primarily on the basis of legitimate interest and specific law: positive data is mostly processed under specific law (50%), while negative data is mostly processed under legitimate interest (59%). Consent remains relevant for a smaller group of CRAs. Almost all CRAs (97%) are required to keep a record each time a file is accessed, and 74% must provide consumers with their credit file within a defined timeframe (most commonly 15–30 days). 97% of CRAs grant consumers access to their own files, and 76% do so free of charge. The most common delivery methods are paper copy by post (85%) and online access (70%). Consumers have the right to dispute, rectify and erase incorrect data in 97% of CRAs, and 59% mark files as “under dispute” during investigation. Only 24% of CRAs allow consumers to add a comment to their file. More than half of CRAs provide educational or informational materials to support borrowers’ financial health.

There has been a notable increase in cross-border data sharing since the 2020 survey. More than half of CRAs now share data with CRAs in other countries (up from 34% to 59% among CRAs that participated in both editions), and the majority also have access to data from CRAs abroad. 80% of those sharing data do so online via dedicated platforms or interfaces, while 20% rely on offline instruments. However, data sharing with financial institutions in other countries remains limited, with only 26% of CRAs reporting such practices. The main barriers to cross-border data sharing are regulatory constraints, followed by a lack of demand.

The credit reporting industry is at an early stage of integrating ESG into its activities. Only 24% of CRAs currently publish ESG or sustainability reports, and 35% offer ESG-related services. Among those offering such services, the most common are ESG data and analytics (83%), ESG reporting and disclosure (58%), ESG scoring and rating (50%) and ESG risk assessment (50%). ESG services are primarily offered on CRAs’ home markets, with 75% of providers active in only one market. The main source of ESG data is companies themselves (44%), followed by public databases (21%) and manual collection (15%). 35% of CRAs follow a specific ESG framework or standard, with the EU Taxonomy / European Sustainability Reporting Standards (ESRS) being the most widely adopted (83%), followed by the Global Reporting Initiative (75%). The main challenges identified by CRAs relate to data quality, accuracy, availability and reliability, largely driven by an insufficient number of companies providing ESG data and limited public data sources. Currently, 65% of CRAs do not integrate ESG information into their credit reports, 21% provide separate ESG reports, and only 15% offer fully integrated ESG and credit reporting. The main barriers to integration are a lack of reliable data and regulatory challenges (both cited by 35% of CRAs), followed by cost implications (24%).

• The large majority of the ACCIS members completed the survey (39 of 42 CRAs), which means that the survey is representative for the ACCIS members.
• It also provides a good representation of the CRAs in Europe. In total the CRAs that responded to this survey are active in 28 European countries, including 16 of the 27 EU Member States.
• There are large differences among the CRAs in terms of their business models. The large majority of the CRAs are for profit organisations, while a minority is non-for profit.
• There is a large variety in ownership ranging from foundations and governments, to credit associations and a group of banks, to listed and non-listed companies.
• The coverage of the CRAs also varies significantly. In general, those CRAs that collect a larger range of positive and negative data based on a specific law cover more borrowers.

Most CRAs hold and collect information on mortgages, consumer loans, credit and store cards, and borrowing on a current account.
Consistently with the results of the 2012, 2015 and 2017 surveys, the depth of the data on ‘mainstream’ lending products covered by members, such as consumer loans, credit and store cards, mortgages, and overdrafts, is the highest in terms of both negative and positive data.
CRAs on average obtain and supply more negative and positive data across all types of services than in 2017.
Credit application, portfolio monitoring, and identity checking are the most frequently used services by clients of CRAs.
Banks, leasing companies, credit card and retail credit suppliers as well as mortgage providers and credit unions are the most common users of CRAs services.
More than half of the CRAs provide educational materials to help borrowers improve their ‘financial health’.

Nearly half of the lenders have a legal obligation to consult CRAs.
A majority of CRAs reported that the access to public/court data collected by CRAs is permitted, whereas a minority of CRAs highlighted that it is required by national legislation.
About half of the CRAs are subject to specific legal/regulatory schemes for entering the market. A substantial minority of the CRAs are further subject to specific provisions governing them.
More than one-third of the CRAs are subject to direct supervision by a national supervisory authority.
Most of the CRAs process data based on the legitimate interests. But specific laws also form an important ground for CRAs to process data. In some cases, consent is required for the processing of processing of positive data.
Consumers have the right to access their data with CRAs.
Consumers have the right to dispute their data with CRAs, yet less than one-fifth of the CRAs give consumers the right to add comments to their file.

More than one-quarter of the CRAs share data across borders and have access to data from CRAs in other ountries.
Only a minority of CRAs share data directly with financial institutions in other countries.

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