The EBF  has responded to the European Commission’s targeted consultation on PSD2.
The EBF  response notes that overall, PSD2 has contributed to 
increasing levels of innovation, competition and security, consistent 
with the objectives of the Directive. Elements such as Strong Customer 
Authentication (SCA) measures and regulating Third Party Provider (TPP) 
access to payment accounts are welcomed as overall positive developments
 in the payments landscape.
Yet, as it might be too early to comprehensively gauge the impact 
PSD2 has had on the market, any change to the Directive should be based 
on further assessment on a number of areas, keeping regulatory 
consistency as a core principle. Importantly, for TPP access to payment 
accounts, the PSD2 review should seek to set a more balanced 
distribution of value and risk.
As the payments landscape is constantly 
evolving, only a holistic assessment of actual market developments and 
of the different market actors will be able to bring about a 
well-balanced and innovative framework under a possible PSD2 review.
full paper
EBF
      
      
      
      
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