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American Express supports the initiatives by the Commission encourage instant payments across the EU. The design of such initiatives should consider all possible barriers to instant payments to ensure further adoption by consumers and businesses alike. A more developed instant payments infrastructure will open opportunities for payment initiation and acquiring in particular.

We would like to express our concern that the first part of the consultation on Instant Payments (targeted consultation) was published before the end of the deadline for feedback on the Impact Assessment. The SEPA Instant credit transfer ("Instant Payments/ SCT Inst") is an important enrichment of the payments service offering in SEPA, which is well accepted by customers from an actual demand.

Summary Inadequate scope: In the case of loan agreements of small amounts in themselves above EUR 200, there is, in principle, an extremely high amount of processing costs which is disproportionate to the yield – and this is the case for manageable risks as a whole. Therefore, the revision of the Directive should consider whether the lower limit can be significantly raised.

Filed in German · English published by the European Commission

American Express welcomes the opportunity to provide feedback on the European Commission’s proposed revision of the Consumer Credit Directive, and is supportive of the Commission’s efforts to establish a single market for credit with harmonised and strengthened consumer protection measures.

The German Banking Industry Committee (GBIC) takes this opportunity to express its opinion on the draft proposal of the Consumer Credit Directive (2021/0171) published on 30 June 2021. GBIC shares the goal of the Draft Directive of offering consumers a high level of consumer protection (recital no. 12).

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.

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.

GBIC welcomes the opportunity, provided by the European Commission, to give feedback on this proposal for this Directive 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.

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.