Module 15 · Finance around the world
Credit around the world: records, scores and mortgages
How countries record credit histories, why yours does not travel across borders, and how long fixed rates, short fixes and variable rates create very different risks.
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In this lesson
- Tell a negative-only register, a register with positive data and a commercial score apart
- Explain why a credit history usually stays in the country where it was built
- Compare long fixed, short fixed and variable mortgages, and calculate a payment shock
- Describe how lending limits protect borrowers, using Slovenia, France and Brazil
Ana has moved from Ljubljana to Munich. Her new landlord asks for a SCHUFA report. Ana has repaid every loan on time for ten years, yet her German file is nearly empty. Why? And how do credit systems differ around the world?
Three ways to record credit history
A is a database of people’s loans and how they repay. Countries build them in three main ways:
- Negative-only: France’s FICP, kept by the central bank, lists repayment incidents. Lenders look mainly at income, job stability and debt ratio.
- Positive and negative, without a consumer score: Slovenia’s SISBON, run by Banka Slovenije, records loans, cards and overdrafts and whether you paid on time. No consumer score is published.
- Commercial bureaus with scores: a is a number calculated from your record. In the US, FICO and VantageScore run from 300 to 850. In India, CIBIL runs from 300 to 900. Germany’s SCHUFA introduced a new 100–999 score on 17 March 2026. In the UK, three agencies hold records and there is no single score.
Records are national. Move abroad and you usually start with a thin file.
Mortgages: how long is the rate fixed?
The rate structure of a home loan decides who carries the risk of rising interest rates:
- United States: the 30-year loan is the standard, so the rate is fixed for the whole term.
- United Kingdom: borrowers typically fix for two or five years, then . In July 2026 the Bank of England expected a little over 5 million households to face higher repayments by the end of 2028.
- Germany: long fixed periods are common. By law, a borrower can end a fixed-rate loan ten years after receiving it, with six months’ notice.
- Japan: in a 2025 survey, 79% of borrowers had variable-rate loans, 12% a fixed period and 9% a rate fixed for the full term.
- Portugal: mixed-rate loans, fixed first and then variable, made up 73.8% of new home loans in December 2024.
Rules that limit lending
Rules limit how much lenders can lend and how costs can grow. A limit caps loan payments as a share of income.
- Slovenia: loan payments may take at most 50% of net income, and at least €745 a month must remain after loan payments (2026).
- France: total debt payments up to 35% of income, insurance included, and terms up to 25 years.
- Brazil: since 3 January 2024, interest and charges on revolving card debt cannot exceed 100% of the original debt. Home loans can run up to 35 years. Lenders offer equal-principal repayment (SAC), where payments fall over time, and equal-payment annuities.
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