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.
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