On 13 January 2018, the second edition of the Payment Services Directive will enter into force as long as the Luxembourg legislator votes the draft law within the prescribed deadlines. The new legal framework will be supplemented over time by the implementation of a set of technical specifications to be complied with (the “Regulatory Technical Standards”). In addition to extending the scope of the first edition, the new legislation introduces new innovative services for the benefit of users as well as payment service providers (PSPs).
The critical point for traditional providers is that they will have to allow the new PSPs – the Third Party Payment Service Providers (TPPs) – having the necessary approvals respectively having registered with the competent authorities, to access the information of their clients who request it. These service providers will be able to offer clients particular information aggregation services on their financial situation but also enable them to initiate payments from accounts of banking institutions.
If in the past the consultation of financial data on payment accounts, or the initiation of a payment was made through instruments and tools made available by a bank, in the near future, the provision of these payment services may actually involve several new and current players.
Thus, it is essential that current PSPs, including banks, identify the impacts and risks before applying the new legal and regulatory framework to avoid jeopardizing the level of user confidence in electronic payment services.
“In this perspective, and like the commissioning of the first edition of the PSD in 2009, the ABBL supports its members in their analysis and interpretation of this directive through various working sessions bringing together the experts in payment of different banks and other PSPs.”
Past meetings have helped to define a common strategy, to raise certain issues with regard to the draft law and have provided the Chamber of Commerce with observations to include in its opinion. A task force has also been set up to draw up a PSD2 guide for banks, the purpose of which is to facilitate the integration of certain key concepts and provisions of the directive and the future Luxembourg legal framework.
“Everything is being done to help banks adequately and efficiently prepare for the changes introduced by the new directive.”
By Antoine Van den Bulcke, Adviser, Banking Technologies & Payments – ABBL