EMA response to EC targeted consultation of AI in finance
The EMA responded to the EC’s Targeted consultation on artificial intelligence in the financial sector.
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EMA publications
The EMA frequently responds to government and European consultations on regulation that impacts the e-money and payment services industry. Sometimes, we also express our views on issues that are raised in the public domain where we feel it is important to provide an industry input.
Our publications reflect the views of the EMA as whole; individual members’ views may vary from time to time. The public consultation responses are listed below. For further information on these positions, please contact us.
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 to FSB consultation on Recommendations for Regulating and Supervising Bank and Non-bank Payment Service Providers Offering Cross-border Payment Services
- EMA response to FSB consultation on Recommendations to Promote Alignment and Interoperability Across Data Frameworks Related to Cross-border Payments
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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.
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.
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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.
EMA response to MFSA consultation on Financial Institutions’ Prudential Requirements
The EMA responded to the Malta Financial Services Authority Consultation on Financial Institutions’ Prudential Requirements.
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Industry Call To Reconsider Approach On Virtual IBANs
The EMA co-signed a joint industry letter on virtual IBANs:
The EU digital payment industry urges Member States to reconsider the Belgian Presidency proposal to assimilate virtual IBANs to traditional IBANs, and to mandate payment service providers to open a payment account with a credit institution in each Member State they operate in. The result will be to materially reduce the ability of payment service providers operating cross-border to help consumers and merchants manage their payments and overcome IBAN discrimination. More evidence is needed on the risks implied by virtual IBANs, and the potential risk mitigation measures should be assessed against their impact on competition, innovation and consumer choice in the EEA.
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