The European Commission organized a consultation on the revision of the second Payment Services Directive (PSD2) between May 10 and July 5, 2022. This was to assess the application and impact of the directive currently in force on the players it regulates, taking into account the evolution of the payment market, the needs of users, etc. Following this consultation, the European Commission announced its intention to propose an initiative to revise PSD2 for the second quarter of 2023.
In this perspective, France FinTech and its members wanted to contribute to the debates and propose ways to improve the regulatory framework necessary for the development of the fintech ecosystem.
PSD2 has, since its entry into force on January 13, 2018, profoundly transformed European payments by diversifying the service offer and boosting the development of fintech, which notably improves the user experience. The states of the European Union today offer a thriving ecosystem of payment service providers (PSPs) offering more accessible, innovative and secure payments to European businesses and citizens.
However, some barriers to innovation remain:
- Difficulties encountered with the application programming interface (API) solutions implemented by banks, which can lead to frequent interruptions of service.
- Lack of access to all accounts and financial data (savings, investment, etc.) of the client.
- Lack of fluidity of authentication paths creating friction.
- Divergent interpretations by the supervisory authority depending on the country.
- Lack of functional uniformity.
In summary of the proposals of the position paper, it is necessary to go further by:
- Harmonizing guidelines by establishing common standards for access to customer financial data, transaction security and personal data protection.
- Accelerating the development of instant transfers by promoting interoperability between different payment service providers (PSPs) and making this service more accessible to consumers.
- Further opening up the payment infrastructure by enabling PSPs to access national payment systems without facing undue barriers and facilitating consumer access to innovative payment services.
- Continuing the development of Open Banking by encouraging banks to open their APIs and provide quality data to TPPs, while ensuring privacy and data security.
- Clarifying the responsibilities of the actors in the event of reimbursement by defining clear rules for the distribution of roles between the banks and the TPPs in the event of error or fraud on a transaction.