From Comparison Site to Lender: What Your Lending Decisioning Infrastructure Needs to Look Like

The Swedish regulatory reform marks a turning point for comparison platforms (låneförmedlare). To continue operating, these organizations must obtain a license, adapt their infrastructure, and transition from intermediaries to active lenders — a change with major operational and strategic implications.

The application deadline is the end of July 2026, and SFSA processing takes 12–18 months.  

Most platforms have already engaged legal counsel and started preparing their license applications. The operational implications and the technology infrastructure required to run regulated lending operations are less visible at this stage. 

Think about what your business does today. You acquire consumers, show them rates from different lenders, and route them to the bank that fits. The bank makes the lending decision, checks creditworthiness and holds the risk. You earn a commission. 

Under the new regime, your role in the lending process changes significantly. The new regime requires creditworthiness assessments, affordability calculations, and documented decisions that meet SFSA standards. When originating loans directly, the company also holds credit risk and must be able to explain decisions to consumers. The technology requirements are substantial! 

SFSA will assess whether your infrastructure is adequate for the business you intend to conduct. They expect functional compliant systems. Plans or vendor contracts on their own are not enough. Specifically:

Creditworthiness assessment

BFBA Chapter 8 requires a thorough assessment based on income, expenses, and financial circumstances from verified sources. This requires connectivity to both external and internal data sources, affordability calculations (KALP, secured and unsecured debt, housing costs, net income), documented decision logic, and explainable outcomes. CCD2 adds a legal obligation from November 2026 to explain decisions to consumers.

Risk Management

BFBA Chapter 6 requires functional risk management systems and a documented risk appetite. For a company that has never held credit risk, this means building credit risk scoring, configurable rules and thresholds, monitoring, and reporting. The analytical and operational layer needs to exist before you can manage risk in any meaningful way.

AML/KYC compliance

Identity verification, sanctions and PEP screening, automated flagging, ongoing monitoring. The obligations under the new license are substantially broader than what intermediaries had before. 

Audit trails and governance

Complete logs of every lending decision: what data was used, what rules applied, what outcome was reached. It must be possible to replay any decision at any point in time for supervisory review. Policy versioning should make it clear which rules were in effect at any given date. This is what SFSA reviews during supervision. 

Banks and established lenders already have all of this. For platforms that historically focused on routing consumers, this infrastructure may not yet exist internally. 

Once you’re operating under the new license, you’ll be receiving applications directly. If you keep running a consumer-facing comparison channel, you would be processing tens of thousands of loan applications a month. The natural approach is to pull a full credit report on every applicant. In practice, this is enormously wasteful. A recent retrospective analysis performed at a Swedish bank showed a potential of 80 to 90 percent cost savings on your credit bureau data costs. This can be done by utilizing sequenced decisioning and pulling data from public sources before eventually a full credit report.  

This is a better approach: tiered pre-screening, where you apply the right data at the right stage. 

Read more on Pre-Screening in our Article “How Smarter Lending Pre-Screening Is Transforming Customer Acquisition in Lending”.

The platform chosen today should be capable of handling future regulatory developments as well. Policy versioning, decision traceability, flexible rule management, and secure IT architecture aren’t luxury features. They’re what lets you respond to regulatory changes quickly instead of running a costly rebuild every time the rules shift. 

Sweden is a compliance-driven market, and new license holders can expect close supervision, particularly in the early years. The lenders that invest in solid, auditable, future-proof infrastructure will have a much easier time during supervision than those that built the minimum to get through the door. 

The decisioning infrastructure, the creditworthiness assessment, the data connectivity, the audit trails, the pre-screening, is still a blank page. That’s often the area worth focusing on early. It takes the longest to build, it requires the most unfamiliar decisions, and it’s what determines whether the lending business you’re building will actually work.