The importance of affordable housing and the economic relevance for the families of buying a house as well as the need to create an efficient and transparent market in an important sector of the lending activity led the European Union to enact the Directive 2014/17/EU on credit agreements for consumers relating to residential immovable property. The article, after an examination of the EU on the consumer protection model, focused on the implementation of Directive 2014/17/EU in Italian and Polish law, not only in defining the concepts of “personal scope”, “consumer” and “creditor”, but in addressing, the thorny issues of foreign currency loan agreements, advisory services and independent advisors. The general rule of minimum harmonization is not always consistently applied, as maximum harmonization is required on the fields of the right to information, a uniform information set of information and the requirement of the Annual percentage rate of charge (APRC). The minimum harmonization method, the prevailing one for the implementation of the Directive, confirms its validity, meeting the fundamental goals: to safeguard consumer protection in this specific market, and to attempt to create a single internal market for mortgage credits in the European Union, taking into consideration the fact that the real estate market is closely linked to the internal legal order of each country and has been shaped over the centuries, and therefore, the rules governing real estate loans are usually detailed and largely based on traditional domestic solutions.