Author name: Janetta

The EMA has responded to the Irish Department of Finance’s consultation on the implementation of the Payment Accounts Directive (PAD). The EMA supports the aims of the Directive: to improve transparency around fees, facilitate switching between accounts, and ensure access to basic bank accounts. Similar to the response to HMT, the EMA expressed concern about the lack of clarity around the scope of the Directive, and proposed that the scope be more clearly defined. If not, it could bring a wide variety of e-money accounts into the scope unnecessarily, such as prepaid cards or online wallets, which are generally considerably different from bank current accounts in terms of consumer usage and purpose. Read the EMA response.

The Electronic Money Association (EMA) has responded to the FCA’s Call for input on the regulatory barriers to innovation, as EMA members have long had to grapple with regulatory features that prevent them either from developing a viable business model, or from growing beyond a certain size.

In this response, the EMA has focused mainly on EU regulation, as it has the greatest impact on our members, many of whom are authorized in the UK or Gibraltar and passport into other EU member states under the Freedom to Provide Services.

Read EMA response to FCA call for input on regulatory barriers to innovation.

The EMA has responded to HM Treasury’s consultation on the implementation of the EU Payment Accounts Directive (PAD).The EMA supports the aims of the Directive: to improve transparency around fees, facilitate switching between accounts, and ensure access to basic bank accounts. We also support HMT’s proposed approach – to introduce as little disruption as possible to UK firms by aligning the implementing rules with the UK’s existing system. However, the scope of the directive in relation to non-bank payment accounts lacks clarity. As a result it could bring a wide variety of e-money accounts into the scope unnecessarily, such as prepaid cards or online wallets, which are generally considerably different from bank current accounts in terms of consumer usage and purpose. This would lead to significant disruption and cost for UK e-money issuers.

The law implementing PAD is due to be adopted and published by the UK government by 18 September 2016, with certain elements of the requirements applying by early 2018.

[button link=”https://emaprd.wpengine.com/wp-content/uploads/2015/08/EMA-response-to-HMT-Consultation-on-PAD.pdf” style=”download” color=”green”]Download the EMA response (PDF)[/button]

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