European Payment Institutions Federation (EPIF)

European payment service providers (PSPs) are committed to combating #payment #fraud and enhancing transaction security across Europe. EPIF is delighted to share with you its views on the subjective approach to the #authorization of payment transactions and the current concerns of the industry with this approach, notably in terms of the increase dispute risks, the operation challenges and impact on security protocols.   With this in mind, EPIF proposes a three-step recommendation: • Maintain objective authorization criteria;  • Revert the burden of proof post-SCA; and  • Standardize the definitions of gross negligence. Our more detailed views are further explained in the statement below.

EPIF is delighted to share with you its views on #fraud under the PSR and its proposal for a more comprehensive fraud prevention approach. Fraud is a societal risk that jeopardizes the safe functioning of the digital economy. To properly tackle fraud, it is necessary to implement a wide range of tools that allow all the actors in the fraud chain to have the appropriate means to act, both together and individually, based on where they sit in this chain. This includes payment service providers, telecom operators and operators of online platforms. These solutions should emphasize cross-sectoral collaboration, cooperation and education to empower consumers. Given the ramifications fraud and scams can have for society, going well beyond the remit of payments or financial services, EPIF calls on the European Commission to set up a cross-sectoral task force to draft a holistic ‘consumer anti-fraud and scam strategy’. This would bring together DG FISMA, DG CONNECT, DG HOME and DG JUST as well as experts from all relevant sectors including the financial sector, the telecommunication sector, online platforms, civil society consumer groups and law enforcement agencies. You can find our full position below.

The European Parliament plenary adopted the draft report on the Payment Services Directive (PSD3) and the Payment Services Regulation (PSR). EPIF welcomes this vote and is happy to see the prioritization given to the payments package by the European Parliament. The PSD3/PSR will bring significant improvements to the current framework and the European Parliament’s position reinforces important aspects around consumer and data protection, open banking and the swift implementation of the merger between the PSD2 and the E-Money Directive (EMD2). EPIF would like to see some improvements with regards to fraud prevention, strong customer authentication (SCA) and allocation of liability that could further enhance legal clarity in the text. This vote is however an important step. EPIF will continue to closely follow the developments on the payments package and monitor its impact on payment markets.  

The European Parliament’s Economic and Monetary Affairs draft report on the Financial Data Access proposal (#FiDA) was adopted today. EPIF is pleased to see that significant improvements are brought to the proposal, notably on the set up and development of financial data access schemes, requirements for common standards and technical interfaces and on the interplay of FiDA with other legislations. EPIF would however still see a benefit in having a staged-approach based on use cases for the implementation of the proposal and remains concerned with the exclusion of designated gatekeepers from being eligible to become a Financial Information Service Provider. EPIF will continue to closely follow the developments on the file and monitor its impact and potential opportunities for the payments market.  

EPIF is delighted to share with you the joint statement co-signed with other industry representatives to highlight a common concern with the treatment of merchant initiated transactions (MITs) within the proposal for a #payments services regulation (#PSR). The new proposal extends the unconditional refund rights under Article 62(1) that exists for direct debits to all other MIT transactions. This implies that payers would be able to request a “no questions asked” refund from payment service providers (PSPs) within eight weeks of any MIT. We would encourage co-legislators to consider removing this obligation for unconditional refund rights for MITs, with the exception of direct debits. You can find below our joint industry letter which explains this issue in more detail.

EPIF, together with other EU Associations, continues to call on co-legislators to reconsider the proposed rules for exempting certain low-value, low-risk e-money products from the requirements under the #AML Regulation. Both consumers and retailers greatly benefit from the current e-money exemption under the 5th AML Directive which should thus be maintained in the AMLR. In particular, we recommend co-legislators to: ➔ Support the e-money exemption in Article 15 (3) per the EP’s proposed text ➔ Remove the restriction to "a single Member State" ➔ Remove the reference to a "direct commercial agreement with a professional issuer" ➔ Support Article 22 (1) (c) in the EP’s proposed text The full Joint Call for Action can be found on the EPIF website: https://lnkd.in/d2CqF5jh

Our last panel of the day has just finished. Thank you to Marcus Härtel, Julia Kowalski, Ninja Reggelin and Hartwig Gerhartinger for an insightful discussion on the Digital Euro. We were delighted to hear the European Central Bank’s views on the key elements of the Digital Euro and the next steps of the new phase of the project. EPIF is following closely the technical and legislative developments of Digital Euro and is committed to continue the discussions for delivering a Digital Euro that brings as much value as possible to citizens, businesses and public authorities.

A timely discussion on the new Open Finance framework. Drawing on the experience with Open Banking, EPIF recognizes the benefits of extending this approach to the entire financial sector. Panellists reflected on the potential of this new framework and the benefits is might bring to consumers and businesses. With a lot of questions to be answered, speakers have given us food for thought. Thank you to the speakers: Mattias Levin Gabriel CUMENGE Fanny Rodriguez Marcel Trik Agustín Reyna Moderator Nickolas Reinhardt 

In light of the recent developments of the SPAA Scheme, panellists took stock of the evolution of the scheme and discussed key next steps. With the proposed new framework for Open Finance, the lessons learnt from the setup of the SPAA Scheme become even more relevant. Giorgio Andreoli, Hartwig Gerhartinger and Jan van Vonno provided some insights on this in a discussion moderated by Fanny Rodriguez.

Lídia Pereira Member of the European Parliament highlighted the importance of considering the overall picture in the payments space with various files currently at the table such as the PSD3, PSR, Digital Euro and Open Finance. Lídia also drew attention to the impact of new technologies and the key challenges of the ongoing comprehensive reform in the payments space.