EPIF is pleased to share its position paper on the EBA Guidelines on PI Insurance for PSPS’. There appears an over-reliance on insurance to underpin the new TPP market. This appears to be the assumed solution even in the title of the ‘Guidelines on Professional Indemnity (PI) insurance for PSPs’. This is unfortunate since there is no such market existing today. If this unavailability becomes a barrier to entry to small TPPs this would seem directly contrary to the intentions of PSD2 to encourage TPPs to flourish.