The EMA sent a letter to the European Commission on e-money for the purposes of considerations in the context of the review of PSD2. The paper addresses the status of e-money in comparison to deposits, and also in relation to payment accounts as well as other topics we touched upon during our conversations.
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.
The EMA submitted a response to the UK Payment Systems Regulator CP23/10: Specific Direction on FPS participants – implementing the reimbursement requirement.
The EMA co-signed an industry letter addressed to the European Commission on IBAN discrimination:
“We urge policymakers and national competent authorities to take a new approach in combating the issue of IBAN discrimination – a practice that has been prohibited for nearly a decade, but which is still widespread across the EU and prevents consumers and businesses from making payments or getting paid. According to data collected by the Accept My IBAN initiative, every month hundreds of people complain that they can’t pay for their phone contracts, rent, newspaper subscriptions, electricity bills, gym memberships, or public transport. What is even more worrying is that in some cases, an IBAN starting with the ‘wrong’ letters can prevent consumers from receiving tax rebates, unemployment benefits and social security payouts.
“Unfortunately, the lack of enforcement, action and strategy to put an end to IBAN discrimination leaves consumers without access to basic services when moving to or purchasing services in another Member State. It also makes companies perceive the EU as a fragmented market where it is harder to do business. As an industry, we call for clear rules, concrete actions and cooperation to stop discrimination.”
The EMA submitted a letter to the Bank of Lithuania on the maximum level of fees to be paid by market participants for financial market supervision in 2024.
The EMA submitted a response to the Malta Financial Services Authority consultation on Changes to Chapter 3 of Virtual Financial Assets (VFA) Rulebook.
The EMA responded to UK HMT’s “risk-based approach to payments” policy questions.