EPIF is pleased to share its response with the ESAs emphasising the need to ensure that the legislation in practice works also when non-bank PSPs are involved in the payment chain. EPIF is of the view that the following two principles must be made clear: 1) The bank where the Payer initiates a payment transaction needs to provide a sufficient amount of input/templates to allow it to obtain sufficient information about the Payee aso when non-bank PSSs act as intermediary PSPs or PSPs of the Payee. 2) Banks that take reciept of payments (intermediary PSPs) need to provide or make available to the holder of the account where the transfer is recieved the same information about the identity of the Payer that the banks have recieved from the Payer’s bank, so as to allow non-bank PSPs to act as PSP of the Payee.