EPC response on Commission Communication for Payments

12 March 2004

In its response to the Communication on a new legal framework for payments the European Payments Council (EPC) holds the view that wholesale and interbank payments should remain excluded from the scope of new legislative proposals. The commissions initiative should aim to harmonise current legislation and not to introduce new legislation whereby self-regulation should be promoted wherever possible.

The EPC also sees a danger that well-intended legislation may hinder competition or discourage potential new entrants to the payments market. The European banking industry believes the framework must recognise the responsibilities of all stakeholders, including Payment Services Providers, supervisory and oversight authorities (ECB and ESCB), market participants, and EU legislative bodies.

Summarizing the key message, the EPC states the following issues:

Avoid disruption of efficient domestic infrastructures

Ensure a level playing field, striking a balance between open access and prudential oversight / risk management

Concentrate on legislation which creates transparency and legal certainty for consumers, but avoid defining technical standards

Recognise the complexity of the payments arena – e.g. avoid a ‘One Size Fits All’ approach

Promote self-regulation wherever possible

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© EPC