Peer-to-peer loans: how a loan reaches lenders and what each holds
A P2P loan reaches a lender as a direct loan, an assigned claim or a Note. ESMA's 2024 ECSPR data put the average loan-based project at about €240,000.
Updated: 2 October 2026
A peer-to-peer loan reaches a lender in Europe as part of a direct loan, an assigned claim or a Note. Each route gives different rights against the borrower. ESMA's report of 22 December 2025 puts the average loan-based crowdfunding project among the ECSPR providers covered in its 2024 data at around €240,000 (ESMA).
Direct loan, assigned claim, Note and invoice: the lender's legal position
Five lending structures carry a loan from borrower to lender, and invoice trading is listed beside them for comparison. Which route applies decides who signs with the borrower and what the lender can enforce. In the table, "originator" means the company that signs the loan with the borrower, which Mintos calls a lending company.
| Route | Example and source date | Contract with the borrower | What the lender holds |
|---|---|---|---|
| Direct loan, property-backed | Estateguru User Terms, effective 23 July 2026 | Under clause 5.10 a loan agreement is concluded when investors agree to satisfy the borrower's application | A loan claim; the Security Agent holds the collateral in its own name to protect the investors (clause 12.2) |
| Originator loan, claim assigned | PeerBerry User Agreement, effective 12 February 2026 | Loan agreement between the loan originator and the borrower | Claim rights bought through an assignment agreement; the user becomes a creditor and may not contact the borrower (clause 9.6) |
| Originator loan, claim assigned, platform as collateral agent | Maclear terms and conditions, version of 4 April 2024 | Loan agreement between Maclear and the borrower (clause 3.6) | Part of the loan receivable bought from Maclear, which acts as collateral agent for investors (clause 3.7) |
| Note | Mintos, read 2 October 2026, and Mintos help, updated 23 September 2024 | The lending company issues the loan from its own balance sheet and lists it on Mintos | A Note from a special purpose entity of the Mintos group, with exposure to a Set of 6 to 20 loans. The Notes issuer holds legal title to the receivables, and investors have no direct recourse against the borrower |
| Portfolio-linked product | Go & Grow report, 13 July 2026 | Bondora Group originates the loans; Go & Grow does not issue loans | Go & Grow says investors legally own loan claims (security page). Bondora Group's 2025 report says receivables are sold to investors and cash flows passed through |
| Invoice | iwoca guide to invoice trading, 14 April 2025 | A business sells its unpaid invoice to investors through an online platform | The invoice or a part of it, bought by bid; the business receives an advance typically of 70% to 90% of the invoice value |
Platform, originator and issuer can be three separate companies, so the lender's counterparty is the entity named in the contract clause.
A German law firm explained on 31 March 2021 that the traditional German model uses a fronting bank. According to the firm, that bank grants the loans and sells the receivables to investors. The firm adds that the Crowdfunding Regulation lets investors lend directly to a company when the provider is authorised (Paytechlaw). For that regulation, see the crowdlending guide. The types of crowdfunding guide places loans next to equity and reward models, and the terminology guide separates crowdlending from crowdfunding.
Funding sequence: investors first at Estateguru, originator first at Mintos
At Estateguru the investors' money reaches the borrower after the funding closes. An investor who consents is legally bound by the loan agreement. The amount is also debited from the investor's account (clause 5.10.5 of the User Terms). A loan application expires if it misses the minimum funding target by the end of the syndication period. Up to 14 calendar days may be added to that period by the platform operator (clauses 5.10.2 and 5.10.3). Estateguru says the capital is transferred once the full loan amount is funded. Typical loan terms, the company adds, are 12 to 18 months (Estateguru, modified 4 September 2026). Its borrower page quotes syndication times from a few minutes to two weeks and targets an application review within 24 hours (modified 11 May 2026).
Mintos, however, reverses the order. Here the lending company issues the loan from its balance sheet and then places it on the platform for investors (Mintos, updated 24 July 2024). At PeerBerry and Maclear the loan agreement is between the originator and the borrower, and the investor's assignment transfers a claim under it.
Servicing and collections: who chases a late payment and what each trigger does
The originator, a collateral agent or the platform chases a late payment. Published trigger days run from 3 to 90 across five platform examples. Delay, buyback and default are separate events, and the risks guide lists the losses that follow when a buyback fails.
- Estateguru. After a missed payment the operations team makes contact, then sends warning letters with an additional deadline of typically seven days. A debt committee follows, then a termination letter with a final deadline of usually fourteen days, and the collateral agent engages local legal partners. Auction proceeds first cover enforcement costs. A €750,000 loan to UAB Seltex was issued in June 2021 and defaulted by the end of 2022. The loan returned investors' principal in March 2025 (Estateguru, published 9 April 2026).
- Mintos. The lending company contacts the borrower and reschedules the loan where feasible. As a last resort, it starts recovery itself or through an outsourced debt collector. The process differs by lending company (Mintos help, updated 21 April 2022). A buyback obligation applies when a loan is more than 60 days late (Mintos, 7 December 2022).
- PeerBerry. The buyback obligation triggers when a loan is more than 60 days late (PeerBerry help, read 2 October 2026).
- Maclear. Clause 3.7 starts an analysis of remedies after 3 days. Under the same clause, soft debt collection starts after 30 days. Legal proceedings and collateral enforcement start after 60 days (terms, version of 4 April 2024). Its FAQ of 10 September 2026 says the Provision Fund covers outstanding interest once a borrower is more than 3 days late. The FAQ also says Grant Thornton AG audits the statements that include it.
- Go & Grow. Bondora defines a default as payments more than 90 days overdue with the customer contract terminated. Collection starts on the first day of delay by email, SMS and automated calls. Its recovery model assumes €667 per €1,000 defaulted in Estonia over ten years (Go & Grow, 13 July 2026).
What borrowers pay: APR and fee examples from platform pages
Borrowers pay interest plus platform fees. The published examples run from business loans at 6% a year in the UK to a 15.49% to 44.97% APR on an Estonian consumer loan.
| Platform and loan | Published cost | Source date |
|---|---|---|
| Bondora, Estonia, €100 to €20,000 over 6 to 120 months | APR 15.49% to 44.97%; example of €3,000 over five years: €98.57 a month, 39.95% representative APR, contract fee €178, total charge €3,092.18 | Read 2 October 2026 |
| Estateguru, real estate loans secured by a mortgage (borrower page) | Interest from 0.6% a month; maximum loan-to-value 75%; average loan €120,742 over 14.2 months | Modified 11 May 2026 |
| Estateguru fees (price list) | Intermediation fee 2.5% to 4%; annual administration fee 0% to 2%. On overdue amounts, a debt management fee of 8.75% and a realisation fee of 10% of principal | In force from 1 November 2025 |
| Rebuilding Society, UK business loans of £25,000 to £250,000 | From 6% a year, with discounts for security | Read 2 October 2026 |
| Rebuilding Society invoice finance | Advance of up to 100% of the invoice value within 48 hours; fees described as fixed, with no percentage on the page | 14 June 2026 |
Check the Bondora example: €2,914.18 of interest plus the €178 contract fee equals €3,092.18. As an illustration at Estateguru, a €100,000 loan carries €2,500 to €4,000 of intermediation fee. At the lowest listed rate of 0.6% a month, simple interest adds €7,200. Interest is calculated at 0.6% a month on the full €100,000 principal held for all 12 months. Bondora's APR and Estateguru's interest and fees measure different costs for different borrower types. However, Estateguru's borrower page quotes the intermediation fee as 3% to 4% where the price list says 2.5% to 4%. Separately, Estateguru reports a 9.96% weighted average interest rate on Baltic loans issued since 2023, at an average loan-to-value of 54.1% (Estateguru, 22 July 2026).
Who can borrow: businesses under ECSPR, consumers outside it
Under Regulation (EU) 2020/1503 (ECSPR), borrowers are project owners. Article 1(2)(a) excludes services provided to project owners that are consumers as defined in the Consumer Credit Directive (legislation.gov.uk).
Article 2 defines a loan as an agreement under which an investor makes an agreed amount available for an agreed period. In that agreement the project owner assumes an unconditional obligation to repay. Project owners are defined there as any natural or legal person seeking funding through a crowdfunding platform (Article 2). Offers above €5 million over twelve months also fall outside it under the same Article 1.
Platforms state their own borrower rules. Estateguru's clause 1.4 says it does not provide or broker loans to consumers. Clause 5.1 requires real estate or real estate rights as collateral (User Terms). PeerBerry lists short-term loans of up to 180 days, long-term loans of 180 days to 4 years and leasing loans among its types. It describes the first two as private consumer loans (PeerBerry, modified 28 July 2026). Bondora's Estonian page, read 2 October 2026, asks borrowers to be 18 to 53 years old. Borrowers are further asked to live permanently in Estonia and to have regular income.
In the UK the FCA describes peer-to-peer crowdfunding as connecting borrowers directly with lenders. It further states that FSCS compensation is not available for it (FCA, 10 July 2026).
P2P loans FAQ
Do I lend directly to the borrower on a P2P platform?
Sometimes, depending on whose name the terms give as creditor. Clause 5.10 at Estateguru binds each investor to a loan agreement with the borrower. PeerBerry's definitions make the originator the creditor until an assignment agreement transfers the claim, and at Mintos the Notes issuer holds legal title. That clause shows who holds the claim before any money moves.
Can a lender contact a borrower who is late?
No on PeerBerry, where clause 9.6 bars the assignee from contacting the borrower. Mintos states that investors cannot pursue the borrower independently. So the originator, the platform or a security agent acts instead, using the steps in the collections section above.
What happens if the originator that owes a buyback fails?
An originator's buyback may go unpaid. Mintos says the obligation is only as good as the company that undertakes it (Mintos). PeerBerry describes a group guarantee under which other Aventus Group and Gofingo Group companies cover the liabilities of an insolvent company (PeerBerry help).
Does the EU crowdfunding regulation cover consumer loans?
No, because Article 1(2)(a) of ECSPR excludes services provided to project owners that are consumers under the Consumer Credit Directive. Each platform's terms, such as Estateguru's clause 1.4, state which borrowers it accepts.
Is invoice trading the same as a P2P loan?
No. The iwoca guide describes a sale: the business sells its unpaid invoice and investors bid to buy it. Advances typically run from 70% to 90% of the invoice value, and the investor's return depends on the invoice being paid.