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The German Banking Industry Committee (GBIC) welcomes the opportunity to respond to the call for evidence on the European Commission’s open finance framework initiative. The following comments supplement our response to the Commission’s targeted consultation on 5 July 2022.

With the draft Framework for Financial Data Access (FIDA), the EU Commission aims to facilitate access to customer data for a wide range of financial services. This is intended to promote the exchange of data between companies in the financial sector as a whole. Thus, FIDA sets the regulatory framework for open finance.

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.

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.

European Digital Finance Association and its members representing thousands of fintechs throughout Europe welcome the proposed regulation to cater for speed in payment transfers in the consumer perspective. We acknowledge the fact that the financial system is not able to provide instant payments to European citizens at large.

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.

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.

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.

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.