Structural Barriers for a European Internal Market in Consumer Credit Information Systems and the European Free Movement Rights: the Case for Institutional Reform

This paper examines the state of affairs of consumer credit information systems in the EU in view of a single retail credit market. It suggests that the industrial organisation and institutional structure in place contravene the fundamental European free movement rights and present structural problems that impede a European dimension to the cross-border exchange of consumer credit data. Ultimately, they constitute a barrier to the creation of the Internal Market. Thus, to the extent that information sharing devices are important for a thriving European market in consumer credit, the EU legislator should start to re-think an institutional reform and a new form of governance.