Consultations

The EMA monitors and frequently responds to government and European consultations on regulation that impact the e-money and payment services industry. The relevant regulatory proposals and consultations are listed below.

Joint industry letter on Eurosystem policy statement on non-bank PSP access

The EMA co-signed a joint industry letter to the European Central Bank expressing concerns over the Eurosystem policy on non-bank PSP access to central bank-operated payment systems and accounts. The letter advocates for a calibrated approach to safeguarding funds with central banks, addressing economic barriers to direct participation, and extending transitional periods to ensure business continuity and maintain competition in the financial services sector.

Read the full letter here

Joint industry letter on Eurosystem policy statement on non-bank PSP access Read More »

EMA response on FSB recommendations for data flows in cross-border payments

The EMA responded to two Financial Stability Board (FSB) consultations on recommendations for data flows in cross-border payments:

EMA response on FSB recommendations for data flows in cross-border payments Read More »

Open Letter from Electronic Money Association to Chancellor Rachel Reeves on APP Scams Reimbursement deadline

The Electronic Money Association (EMA) sent a letter to Chancellor Reeves outlining our concerns regarding the implementation of the Authorised Push Payment (APP) mandatory reimbursement scheme. We have also written to the Economic Secretary to the Treasury.

As the EU trade body representing electronic money issuers and alternative payment service providers, we have highlighted several critical issues that need addressing before the scheme’s full implementation. These include concerns about the financial burden on smaller Payment Service Providers (PSPs), potential delays in system readiness, and the need to reconsider the maximum claims threshold.

We believe these matters are crucial for ensuring the scheme’s success and alignment with the broader goals of economic growth and innovation. We would very much appreciate the opportunity to discuss these concerns in further detail and explore potential solutions that could benefit both consumers and the payments industry.

Read EMA’s full letter here

Open Letter from Electronic Money Association to Chancellor Rachel Reeves on APP Scams Reimbursement deadline Read More »

EMA response to FATF Public Consultation on National Risk Assessment Guidance update

The EMA submitted a response to the Public consultation on FATF Money Laundering National Risk Assessment Guidance Update emphasising the value contributed by the private sector, civil society, and academia. These sectors provide insights on emerging risks, facilitate effective communication with authorities, and offer frontline experience in the fight against financial crime. Furthermore, the EMA advocates for countries to engage the private sector in NRAs through public consultations and workshops, enabling comprehensive input, discussion of business models, risks, and mitigation measures, and the formation of public-private partnership groups to promote regular knowledge exchange and mutual understanding.

Read EMA’s full response here

EMA response to FATF Public Consultation on National Risk Assessment Guidance update Read More »

Joint industry letter on the application of PSD2 provisions to a various EMT transactions

The EMA co-signed a joint industry letter addressing the application of PSD2 provisions to electronic money token (EMT) transactions. The letter urges the European Commission to distinguish between EMT-related activities, such as custody and trading, and regulated payment transactions under PSD2. It advocates for pragmatic regulatory approaches, extensions of compliance timelines, and ongoing engagement to ensure an appropriate framework for EMT operations across the EU.

Read the full letter here

Joint industry letter on the application of PSD2 provisions to a various EMT transactions Read More »