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Market participants and competent authorities are facing a number of issues and challenges in the transition from PSD1 to PSD2. Given the cross-border nature of retail payments, the EBA and the national competent authorities have a shared interest in ensuring that these issues are addressed consistently across the EU and that the transition from PSD1 to PSD2 proceeds smoothly and transparently for payment service providers across the EU.
PSD2 has conferred on the EBA the development of twelve Technical Standards and Guidelines covering a number of different areas, including authorisation, passporting, payment security, account access, and consumer protection. However, by the application date of PSD2, 13 January 2018, some of the EBA deliverables will not yet be applicable, either because they have not been completed or because PSD2 itself envisages that certain security-related provisions will be applicable after its application date. Finally, PSD2 also foresees that some groups of providers will not have to comply with all PSD2 requirements from its application date.
Against this backdrop, the EBA in its Opinion conveys a number of views and provides advice to competent authorities on how to address these issues.