17 January 2020

EBF’s views on the evaluation of the Payment Accounts Directive

EBF notes that the recent transposition deadline of the Directive means that its complete impact and capabilities have still to fully unfold and it is impossible, at this point in time, to have a full assessment of the impact of the Directive in the market.

The EBF therefore strongly encourages that monitoring the impact on both consumer and market trends be continued to ensure that the Directive has been in place for sufficient time to identify potential impacts. Only if any needs emerge, then changes to the text can be proposed. Against this background EBF recalls that regulatory stability is valued by both customers and market participants and EBF encourages legislators to grant it. 

Several consumers’ satisfaction surveys undertaken in different member states show that consumers are well aware of and very satisfied with the switching services offered by their providers. For example, in a member state a 2019 study showed that awareness and satisfaction levels for the Current Account Switching Service remained consistently high at 79% and 92% respectively. A high level of consumers’ satisfaction with the switching services should be the target of policy actions, and not a high level of switching per se, the latter would result in providers not being able to fulfil customers’ expectations. As a result, EBF cautions against looking at the level of switching as a target in itself and advises introducing further initiatives, that would not be necessarily used by customers. Implementing such measures would increase the costs of services without providing added value to customers who are not interested in switching, or to those who already use such a service (and are happy about it according to surveys).

In line with the above, EBF also strongly recommends refraining from introducing IBAN portability requirements without a detailed cost-benefit analysis clearly showing that the benefits for consumers outweigh the impact of a measure that would heavily damage the EU payment system.

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