Payment services in the internal market

The Electronic Money Association (EMA), established in 2001, is the trade body for European and UK Crypto Assets Providers (CASPs), Payment Institutions (PIs), E-Money Institutions (EMIs), and Credit Institutions (CIs) providing innovative payments.

In France, lassociation des Sociétés Financières (ASF) represents in France the activities of financing specialising in credit and in financial and investment services. Its 270 members are active in the service of businesses and professionals (factoring, leasing of furniture and real estate, financing of energy) and households (consumer credit and housing credit).

Filed in French · English published by the European Commission

European Digital Finance Association (EDFA) welcomes the opportunity to share its position on the EU payment services legislative package presented by the European Commission on 28th June 2023. EDFA hopes that the proposals will help to further level the playing field between bank and non-bank payment providers, as well as modernise and enhance the resilience and competitiveness of the payment sector.

American Express (Amex) welcomes the proposed Payments Services Package introduced by the European Commission (EC) in June 2023, as these proposed changes will help to foster innovation, strengthen competition, and secure safer payments. Overall, this package marks an important step towards harmonizing payment standards across the EU.

The Open Finance Association (OFA) welcomes the European Commissions proposal on payment services in the internal market and amending Regulation (PSR) and the proposal on the third Directive on payment services and electronic money services in the Internal Market (PSD3). We support the Commissions approach of a natural evolution to the current rules in the second Payments Services Directive (PSD2).

SIBS welcomes the opportunity to provide feedback and contribute to the European Commissions legislative proposal for a Regulation on payment services (PSR), which is part of the package to review the current legal framework (PSD2).

Please find attached the Position Paper of the Association of Foreign Banks in Germany (VAB) of 1 November 2023 on the Proposal for a REGULATION OF THE EUROPEAN PARLIAMENT AND OF THE COUNCIL on payment services in the internal market and amending Regulation (EU) No 1093/2010 [COM (2023) 367 / Procedure 2023/0210/COD].

Finance Denmark welcomes the Commissions Proposal for a Regulation on payment services in the internal market (PSR). We have the following comments to the proposal: Open banking The Commission proposes to continue PSD2's principle that; account servicing payment service providers should allow access by providers of open banking services to payment account data and that this should take place in a non-contractual…

In Attachment: CharIN e.V. Position Paper with full explanation. Executive Summary In light of the European Commission's ongoing review of the Payment Services Directive (PSD2) with its proposals issued on June 28th, 2023, and the relevant request for feedback, we welcome the opportunity to address emerging challenges in the context of the implementation of the EU Alternative Fuels Infrastructure Regulation (AFIR)…

1 (3) The Swedish Bankers' Association's response to the European Commission’s proposal for changes in the regulatory framework for payment services Swedish Bankers’ Association welcomes the opportunity to provide the European Commission with its comments on the proposal for a Regulation of the European Parliament and of the Council on payment services in the internal market (PSR proposal).

Opening of the attached position paper · the full paper is on the Commission’s record (source link above)

COMMENTS OF THE POLISH CONFEDERATION LEWIATAN ON THE PROPOSAL FOR PSD3 AND PSR In connection with the legislative work on Proposal for a Regulation Of The European Parliament And Of The Council on payment services in the internal market and amending Regulation (EU) No 1093/2010 (hereinafter PSR) and Proposal for a Directive Of The European Parliament And Of The Council on payment services and electronic money…

Opening of the attached position paper · the full paper is on the Commission’s record (source link above)

IPF hopes that the proposals will help to further level the playing field between bank and non-bank payment providers, as well as modernise and enhance the resilience and competitiveness of the payment sector. For the upcoming legislative procedure, IPF urges lawmakers in the European Parliament and the Council to use the revision of PSD2 as an opportunity to avoid excessive requirements and increased bureaucracy.

PSR art 2(2)(b) proposes to narrow down commercial agent exemption. As a result many marketplaces would have to obtain a payment services license (or arrange sellers to hand payments over to licensed providers), which is likely to reduce availability of digital payment methods for both buyers and sellers. Related payments' specific risk is low and not worth regulatory resources.

First, we welcome the decision to introduce a regulation that includes provisions on payment services, transparency, and rights and obligations, consistent with the regulators' intention to create a level playing field for PSPs at the European level.

Comment on Article 59 of the PSR1 proposal: The PSR1 proposal identifies an error in PSD2: in a context of fraud, the diffuse difference between authorised and unauthorised transactions, owing to a defect in consent or even lack of consent. However, it seeks to amend it in Article 59 in a way which, in our view, is contrary to the principles of law.

Filed in Spanish · English published by the European Commission

Comment on Article 55 of the PSR1 Proposal It is positive that the proposed Regulation is not unrealistic and addresses in the preamble one of the biggest problems faced by payment service providers: the disproportion and high financial cost they bear when opening each fraudulent transaction, whether authorised or not, to a systematic reimbursement right in cases of impersonation, see recital 79.

Filed in Spanish · English published by the European Commission

As the private sector operator of the pan-European SEPA payment systems STEP2-T and RT1, EBA CLEARING welcomes the opportunity to provide feedback on the proposed Payment Services Regulation. For your consideration, in the attachment, EBA CLEARING has suggested specific amendments to the proposal wording, along with the reasoning behind each proposed amendment.

My name is Andrea Castillo Olano. I am a doctorate in commercial law and for the last 4 and a half years I have investigated the legal status of payment services in both Spain and Europe. Please find in the attached document my comments on the Proposal for a Payment Services Regulation, based on the findings and conclusions of this enquiry.

Filed in Spanish · English published by the European Commission

Mastercard welcomes the Commission's legislative proposal on PSR, and its ambition to improve upon the existing PSD2 regime. We welcome the measures aimed at making the payment ecosystem even more resilient to fraud, and also the initiatives to further streamline the Open Banking ecosystem.

GSMA Feedback to the European Commission’s Proposal on Payment Services in the Internal Market This document presents the inputs from the GSMA to the Proposal for a REGULATION OF THE EUROPEAN PARLIAMENT AND OF THE COUNCIL on payment services in the internal market and amending Regulation (EU) No 1093/2010 open feedback period.

Opening of the attached position paper · the full paper is on the Commission’s record (source link above)

ETPPA has contributed heavily to the European Commissions review of PSD2, and we are pleased to see that some of our recommendations have been reflected in the proposed package published on June 28. ETPPA strongly supports the Commissions proposal to review PSD2 and is pleased to see the Commissions vision to reaffirm open banking in Europe.

Febelfin, the Federation of the Belgian Financial Sector, has assessed the Commissions proposal for a Payment Services Regulation in detail and welcomes some necessary updates that can ensure that the legislative framework reflects the current state of the payments market, provided that some important elements are integrated, most notably on fraud (prevention) and liability and open banking.

The European Commission presented a Payments Package to bring payments and the wider financial sector into the digital age, including a proposal for a Payment Services Regulation (PSR). Adigital welcomes the opportunity to provide feedback to the EU Commissions proposal on Financial Data Access and revision of the Payments Services Directive (PSD2).

Dear Sir/Madam, we ask you to find the points of satisfaction with this proposal and also our concerns about the effects of the various new provisions in the attached document. We would like to draw the attention of the European Commission to some crucial points for a more effective and balanced implementation of the proposals.

Filed in French · English published by the European Commission

Berlin, 27 October 2023 BDEW Bundesverband der Energie- und Wasserwirtschaft e.V. [address removed] www.bdew.de BDEW Position Paper Payment Service Regulation (PSR III) The German Association of Energy and Water Industries (BDEW) and its regional organisations represent over 2,000 companies. The membership comprises both privately and publicly owned companies at the local, regional and national level.

Opening of the attached position paper · the full paper is on the Commission’s record (source link above)

We welcome the choice of a Regulation for the provisions on the scope of payment services (PSs), transparency and rights and obligations as it goes in the direction to create a uniform EU regulatory framework avoid fragmentation and competitive disparities. We agree that the proposals entail an evolution of the payment sector leveraging the investment already made (e.g.PSD2 dedicated interfaces).

The European Association of Co-operative Banks (EACB) welcomes the opportunity to provide feedback on the European Commission's proposals for a Payment Services Regulation (PSR) and Payment Services Directive (PSD3). The EACB actively contributed to the PSD2 review process with our input reflecting the views of cooperative banks across the EU.

EURO 6000 appreciates the opportunity to provide feedback on the European Commission Proposal for a Regulation on payment services in the internal market, published on 28th June 2023. With our response we would like to highlight several improvements and clarifications that could be made in the proposed regulation to achieve its objectives. Please find attached our comments.

CECA (Spanish Association of Savings and Retail Banks) welcomes the opportunity to comment on the proposal for a regulation on payment services in the internal market (PSR) and amending regulation (eu) no 1093/2010. ).

Payment services: Directive Proposal and European Regulation Proposal OAM considerations OAM – i.e., Organismo per la gestione degli elenchi degli agenti in attività finanziaria e dei mediatori creditizi - receives the opportunity to provide its considerations as part of the European payment services legislation review. Pursuant to article 128 -undecies of the Legislative Decree n.

Opening of the attached position paper · the full paper is on the Commission’s record (source link above)

SVIA welcomes the European Commission proposal for a review of PSD2, including the new Payment Services Regulation (PSR), and the political objectives that are being pursued. SVIA specifically welcomes the continuation of the Limited Network Exemptions (LNE), which remain largely unchanged under Article 2.2.j, and in particular the social vouchers exclusion (2.2.j(iii)) of the PSR.

The EUs payment services legislation has been an important driver of change in how travel technology businesses handle payment transactions. eu travel tech broadly views the revised Payment Services Directive (PSD2) as a piece of legislation that has enabled the development of innovative payment services, increasing competition in the relevant markets and making payments more efficient, swift and secure for…

STMP welcomes the opportunity provided by the European Commission to give feedback on this proposal for a regulation and contribute to the legislative debate. Please find attached our detailed comments on the proposal.

The European Savings and Retail Banking Group (ESBG) welcomes the opportunity to provide feedback to the European Commission's legislative proposal for a new Payment Services Regulation. Please consider the attached ESBG position as our formal response to the Have Your Say consultation.

The Spanish Banking Association (AEB) welcomes the importance assigned to fraud in the proposal of Payment Services Regulation. It enhances the need to prevent fraud (PSPs are very concern about it and take most and probably more measures than those prescribed).

About Redsys Servicios de Procesamiento Redsys is Spain’s largest payment processor, with over 40 years of experience. Redsys enables the vast majority of card payments in Spain, is the main technical provider for Bizum, a highly successful mobile P2P and e-commerce payments platform, and also processes SCT Inst transactions.

Opening of the attached position paper · the full paper is on the Commission’s record (source link above)

Cdiscount welcomes the proposal for a Payment Services Regulation (PSR) and its aims to harmonize enforcement, better combat fraud and improve open banking. Cdiscount takes this opportunity to remind that the introduction of Strong Customer Authentication (SCA) had both positive and perverse effects on e-commerce.

The Digital Currencies Governance Group (DCGG) welcomes the opportunity to provide feedback on the European Commission's proposal for a Payment Services Regulation (PSR). Please find attached our comments. We would be delighted to discuss our response in more detail should there be any questions or points of clarification that may support your assessment.

The European FinTech Association (EFA) welcomes the European Commissions (Commission) proposals for a new Payment Services Directive (PSD3) and Regulation (PSR). PSD2 has delivered a more innovative, competitive payments landscape in Europe, allowing consumers to benefit from new products and services and more secure payments.

Good afternon: I am Carlos Torme, Director of New Market Development at GS1 Spain. I am attaching a comment document on behalf of our merchants (retailers and suppliers operating under the DTC model) along with: The 3 most important card schemes: American Express, Mastercard and Visa.

Hello The French banking profession, through its federation FBF (French Banking Federation), wishes to make its contribution and thus respond to the European Commission's consultation on its legislative proposal on the revision of PSD2. To do so, please find attached the "Have your say" on the draft PSD3 Regulation. Yours sincerely, FBF

GBIC welcomes the opportunity, provided by the European Commission, to give feedback on this proposal for this Regulation and contribute to the legislative debate. Please find attached our detailed comments and positions on the proposal. The German Banking Industry Committee (GBIC) is the joint committee operated by the central associations of the German banking industry.

The Association of Credit Card Issuers in Europe represents the specialised credit card issuing industry in the EU. ACCIE welcomes the Commission's proposals for a new Payment Services Regulation (PSR) and the revision of the Payment Services Directive (PSD3). Our feedback can be found in the attached file.

Wonderbox SAS, a French company engaged in commercial activities in various Member States, all centred around the distribution of experience gift services, both physically and digitally, responds to the proposed Payment Services Regulation (PSR) with two key points: Exclusion of Payment Transactions via Agents: Wonderbox argues that payment transactions conducted by mandated agents should be excluded from the scope…

PAYMENT SERVICES DIRECTIVE (PSD3) & PAYMENT SERVICES REGULATION (PSR) PROPOSALS Ref. Ares(2023)7239037 - 24/10/2023 POSITION PAPER EXECUTIVE SUMMARY October 2023 The overall aims and objectives of the vending industry with regards to bank and credit card payment options are: • To ensure a seamless and convenient payment to the consumer is provided; • To enable the consumer to pay with their preferred method; • To…

Opening of the attached position paper · the full paper is on the Commission’s record (source link above)

Response to European Commission’s adoption of a proposal for a Regulation on payment services in the internal market1. Bizum would like to thank the European Commission for the opportunity to provide feedback on this proposal for a Regulation. Please find below these lines our detailed comments on the proposal. 1. Overview of Bizum. Bizum, S.L.

Opening of the attached position paper · the full paper is on the Commission’s record (source link above)

From AMETIC, the employers of the digital sector in Spain, we appreciate the opportunity to provide information on the European Commission’s proposal on access to financial data and the revision of the Payment Services Directive (PSD2). Details can be found in the attached file.

Filed in Spanish · English published by the European Commission

E.ON appreciates the opportunity to provide feedback on the proposal for a revision of the Payment Services Regulation. E.ON supports the plans of the European Commission to increase the efficiency, transparency and choice of payment instruments for payment services as well as to ensure a high-level protection for payment service users.

The Dutch Payments Association (DPA) organises collective and non-competitive tasks in the national payment system for its members. The DPA and its members welcome the European Commissions proposal for a Regulation on payment services in the internal market (PSR). We have witnessed the Commissions thorough review process of PSD2 and are pleased to see that the Commission has proposed to make targeted amendments.

Fleet Cards Europe (FCE) welcomes the European Commissions review of the PSD2 framework. Since the beginning of the review process, FCE has proactively liaised with the EU policymakers to achieve mutually beneficial outcomes concerning PSD3 and the PSR. We wanted to take the opportunity and participate in this feedback tool to express our observations and concerns on the proposed text.

Wise welcomes the European Commission's proposals for a revised Payment Services Directive (PSD3) and new Payment Services Regulation (PSR), especially the enhanced harmonisation a Regulation will bring. The lack of harmonisation and the differing national interpretations on certain regulatory requirements has been problematic and caused significant challenges for innovative firms to expand across borders.

Public consultation on Payment services – revision of EU rules The second Payment Services Directive (PSD2)1 provides a legal framework for all retail payments in the EU, both in euros and other currencies, domestic and cross-border. On June 28, the Commission published its proposals for legislative changes to PSD2 to enhance its functioning.

Opening of the attached position paper · the full paper is on the Commission’s record (source link above)

DECO welcome this proposal. We consider the PSD2 needs to be profoundly revised especially regarding fraud, liability and redress. General comments: The proposals to address consumer/user confidence by enhancing their protection are very much welcome.