Shared with DG FISMA, European Commission and European Central Bank (ECB), this paper states EPIF’s position on the issues of de-risking and safeguarding in PSD3 and PSR and the effective implementation of the revisions of the Settlement Finality Directive with regards to access to intra-bank payment systems.

Our members have long been concerned about market practices whereby banks make it impossible for the non-bank payment sector to have access to commercial bank accounts to and importantly to safeguarding accounts.

EPIF opposes the indiscriminate nature of the ECB guidance on the implementation of the access to central bank accounts which seeks to differentiate between the use of access to central bank accounts by non-bank PSPs for settlement and safeguarding purposes and the way the ban of access to safeguarding accounts is applied to the non-bank PSPs as a whole. EPIF supports that this makes the non-bank payment institutions overly dependent on the commercial banking sector and the consequences of de-risking.