European Association of Third Party Providers calls on co-legislators to revisit Open Banking provisions in PSR/PSD3

ETPPA calls on co-legislators to revisit Open Banking provisions in PSR/PSD3 in order to level the playing field with other payment service providers and help fight fraud.

Following the June 18 general approach agreement reached on PSR/PSD3 by the Council, ETPPA would like to express its concern that several existential Open Banking considerations pertaining to Account Information Services (AIS) and Payment Initiation Services (PIS) are not reflected in the Council’s negotiating position. 

ETPPA would like to call on the co-legislators to revisit Open Banking provisions in PSR/PSD3 during trilogue negotiations in order to allow TPPs to compete on a level playing field with other payment service providers, and help in the fight against online fraud.

ETPPA calls on the co-legislators to:

1. Revert to the European Commission’s proposed text for Article 38 on contingency measures for an unavailable dedicated interface.
2. Revert to the European Commission proposal on the definition of PIS in Article 3(20), as the Council introduces new wording which would unnecessarily limit the different business models and use cases that can be served by PIS.
3. Ensure Open Banking API (dedicated interface) quality by reverting to the European Commission text for Article 36 as well as adopting the important changes suggested by the Parliament for Article 36 as this is important for the mitigation of fraud and to allow a convenient payment service user journey. Furthermore, the list of prohibited obstacles in Article 44 should not be cut down, as suggested in the Council text, so that open banking can compete on a level playing field. 

Open Banking based on PSD2 is currently – and for the foreseeable future – the only existing electronic payment solution reaching all 400+m payment accounts in Europe and thereby ensuring EU sovereignty if needed. PSR is the opportunity to make it more robust and we cannot afford to weaken it just to please the banks and card schemes. 

These three points must be addressed during trilogue negotiations as an absolute minimum in order to put in place a level playing field for online payments in the EU and help in the fight against fraud. Please see our PSR position here for further recommendations.

Click here to read the full statement.