This article deals with the commercial nature of the consumer pawn loan agreement, regulated by the new Consumer Pawn Loan Act dated 14.04.2023. The legislator allows only entrepreneurs engaged in pawnbroking activities, i.e. limited liability companies and joint-stock companies entered in the register kept by the Financial Supervision Authority, to conclude such agreements. However, the provision defining a consumer pawn loan agreement indicates that any entrepreneur can be a party to the agreement. An analysis of the contradictory provisions of the new law leads to the conclusion that a consumer pawn loan agreement entered into by an entrepreneur who is not a pawnbroker is valid and subject to the provisions of the new law. However, the sanction of a free loan may be applied to it due to the lack of indication of a registration number in the agreement, unless the agreement was concluded by an entrepreneur during the transitional period indicated in Article 57 u.k.p.l.