EPIF is pleased to share its response to the Commission consultation on restrictions on payments in cash. EPIF believes that EU-wide action to restrict payments in cash is unnecessary at this time. Cash remains the payment method of choice for many people, due to its convenience, its portability and its universal acceptance.
EPIF is pleased to share its response to the Article 29 Working Party Guidelines on Data Protection Impact Assessment (DPIA). For EPIF, the central question is what ‘high risk’ means to the regulators and to companies. Companies need legal certainty of how the rules will be applied.
EPIF generally agrees with the proposed Guidelines 1-6 but underlines the importance of the Home State Principle and its application to the complaints procedure for alleged infringements of the PSD2.
EPIF is glad to share its response to the consultation on Central Contact Points. EPID agree with the princple of CCP but is of the view that it is crucial that the EBA provides guidance to Member States on the form of CCPs to avoid Member States to take on different approaches.
EPIFsupports the PSD2’s creation of a central EBA Register, which will serve as a one-stop-shop for consumers and businesses alike to access up-to-date information about the Payment Service Providers (PSPs) they interact with. From a Payment Institution’s (PI) perspective, EPIF is of the view that the Register should provide capabilities for real-time partner verifications through fast [...]
EPIF would welcome confirmation as to whether agents who are not acting on behalf of a PI in providing payment services. The CCP should be able to manage country level reporting to the regulator but it is not necessary for the CCP to conduct its own additional offsite or onsite audits or investigations. EPIF would welcome [...]
EPIF is pleased to have co-signed a letter together with 18 other associations on the draft RTS on SCA. The letter provides the high-level postion of major payments industry operators with regards to the draft RTS on SCA. The letter ackknowledges the need for a Transaction Risk Analysis (TRS), supports a result-oriented approach and encourages [...]
EPIF is glad to share its response to the EBA consultation on the draft Guidelines on the information to be provided for the authorisation as payment institutions and emoney institutions and for the registration as account information service providers.
EPIF is pleased to share its response to the EBA Guidelines on major incident reporting under the PSD2. These draft Guidelines set out the criteria, thresholds and methodology to be used by payment service providers in order to determine whether an operational or security incident should be considered as major and, therefore, be notified to the [...]
EPIF is pleased to share its response to the EBA consultation on the Regulatory Technical Standards on strong customer authentication and secure communications under the PSD2. EPIF is supportive of initiatives that introduce more choice to innovation in the European payments sector and believes that we should adapt to customer needs and the rapid pace of [...]