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.

HM Treasury’s consultation on the implementation of the EU Payment Accounts Directive (PAD)

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.

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HM Treasury’s consultation on the implementation of the EU Payment Accounts Directive (PAD) Read More »

Final EMA response to FCA consultation on complaint handling

The EMA welcomes the opportunity to respond to FCA’s consultation, ‘Improving Complaints Handling’ CP 14/30. The response below addresses the questions that are of particular concern to EMA members: Question 3 on the summary resolution communication, Question 8 on the use of premium rate telephone numbers, and Question 20 on the cost benefit analysis.

13 March 2015     Final EMA response to FCA consultation on complaint handling

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EMA response to EBA’s consultation on the implementation of draft EBA Guidelines

EMA responsed to EBA’s consultation

EMA response to the EBA’s consultation EBA/CP/2014/31 on the implementation of draft EBA Guidelines on the security of internet payments prior to the transposition of the revised Payment Services Directive (“PSD2”)

17 November 2014, EMA response to EBA consultation

EMA response to EBA’s consultation on the implementation of draft EBA Guidelines Read More »

EMA response to call for inputs for the UK Payment Systems Regulator (PSR)

Last year, HM Treasury announced that the Financial Conduct Authority would set up the UK Payment Systems Regulator (PSR). Following the announcement, the FCA published a “call for inputs” consultation in March this year and organised a stakeholder conference. The EMA contributed to the consultation to assist the Payment Systems Regulator develop its regulatory approach and identify early priorities.

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EMA response to call for inputs for the UK Payment Systems Regulator (PSR)Read More »

EMA response to call for inputs for the UK Payment Systems Regulator (PSR) Read More »

ECB consultation on security requirements for the security of mobile payments (deadline: January 31, 2014)

Yesterday, the European Central Bank (ECB) released a draft version of the Recommendations for the security of mobile payments for public consultation. These recommendations were developed by the European Forum on the Security of Retail Payments, SecuRe Pay (the “Forum”). In the Forum all EU supervisors work together with the aim to foster the establishment of a harmonised EU/EEA-wide minimum level of security. The consultation follows two previous consultations on requirements with respect to the security of internet payments and on third party account access.

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ECB consultation on security requirements for the security of mobile payments (deadline: January 31, 2014)Read More »

ECB consultation on security requirements for the security of mobile payments (deadline: January 31, 2014) Read More »

EU Commission proposals for revised Payment Services Directive and MIF-regulation

On 24 July 2013, the Commission adopted a legislative package which proposes a revised Payments Services Directive (PSD2) and a Regulation on Multilateral Interchange Fees (MIFs). The changes in the Payment Services Directive include a.o. changes in scope, the addition of a new type of institution (Third Party Payment Services Processor) and further rules as to transaction authentication. The Regulation on MIFs seeks to cap the interchange fees for card payments to 0,3 and 0,2 % for international credit- and debit-transactions. Over time these limits would also apply to domestic transactions. …

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EU Commission proposals for revised Payment Services Directive and MIF-regulation Read More »