EPIF is delighted to share its position paper on the recent proposals on payment services (PSD3/PSR).

EPIF very much welcomes these proposals, in particular the ambitious approach taken by the European Commission to move towards a Single Rulebook. This is an important step to further deepen the EU’s Single Market for payments and reduce divergences in national implementation that EPIF members have always supported.

This new Package brings many significant improvements to the current framework, levelling the playing field between the bank and non-bank payment sectors through a targeted amendment to the Settlement Finality Directive (SFD), allowing for safeguarding of accounts and reinforcing de-risking provisions. It also enhances the rules for fraud prevention data sharing. EPIF in particular welcomes the progress made in the European Commission’s proposal on Strong Customer Authentication (SCA). Furthermore, the proposal makes important advancements on Open Banking.

Notwithstanding, several provisions still cause concern and introduce frictions in the payments space. This relates to the proposals to merge the PSD2 and the e-money Directive (EMD2), the treatment of current exemptions to the scope, SCA and other provisions around surcharging, liability, refund rights and transparency.

Our full position on the PSD3/PSR can be found below.