Sander bunq does not offer any form of credit/loans.
Michiel 🏳️🌈 The Travelcard behaves just like a real credit card, but without providing credit to the user
I must say your statements sound quite suspect, from a legal standpoint (though that's hardly your "fault"). Because the concept and term of a "credit card" has been defined by EU law - which states that they do entail a credit facility. Which does make a difference compared to debit cards in that credit cards allow for higher interchange fees.
Now I do believe that the latter might not be bunq's primary intention to do so. Still, as both of you put it, it does like a circumvention of the rules. So are bunq flouting the law - or am I missing somewhat here?