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.
Together with Fdata, TechUK and UK Finance, the EMA has developed draft voluntary industry guidance setting out best practice for screen-scraping during the transition period until the RTS on SCA and CSC comes into force in Q3 2019.
The EMA submitted a response to European Commission’s Consultation on Exchange of data to combat VAT fraud in the e-commerce on 25 April 2018.
EMA response to EC Questionnaire on combatting VAT fraud in e-commerce Read More »
The EMA responded to FCA Consultation paper 18/03 on SME access to the Financial Ombudsman Service and Feedback to DP15/7: SMEs as Users of Financial Services on 23 April 2018.
EMA expresses concern about the FCA’s proposals to expand the list of eligible complainants to the Financial Ombudsman Service to include SMEs and guarantors. This is a substantial departure from existing practice, and is likely to have a considerable impact, particularly on smaller financial service providers in the payment services sector, where disputes are likely to be complex, and where the financial services provider may themselves be an SME.
EMA response to FCA CP1803 on SME Access to FOS Read More »
The EMA submitted a response to the Spanish Ministry of Economy, Industry and Competitiveness on the implementation of the Revised Payment Services Directive (PSD2) in Spain.
EMA response to Spanish PSD2 consultation April 2018 Read More »
The EMA submitted a response to Bank of Portugal Consultation on the proposed Notice on the Prevention of Money Laundering and Terrorist Financing (projeto de aviso sobre a prevenção do branqueamento de capitais e do financiamento do terrorismo) on 29 March 2018.
EMA response to Portugal Draft Notice on AML Law Read More »
The EMA responded to the Bank of Italy consultation on the implementation of the Limited Network Exclusion and Electronic Communication Network under PSD2 – ATTUAZIONE DELL’ART. 2, comma 4-BIS DEL D.LGS. N. 11/2010 IN MATERIA DI SERVIZI DI PAGAMENTO – PROVVEDIMENTO BANCA D’ITALIA on 6 March 2018.
EMA response to Italian LNE consultation Read More »
The EMA submitted a letter to the Greek Ministry of Finance on implementation of 4MLD – ΠΡΟΛΗΨΗ ΚΑΙ ΚΑΤΑΣΤΟΛΗ ΤΗΣ ΝΟΜΙΜΟΠΟΙΗΣΗΣ ΕΣΟΔΩΝ ΑΠΟ ΕΓΚΛΗΜΑΤΙΚΕΣ ΔΡΑΣΤΗΡΙΟΤΗΤΕΣ ΚΑΙ ΤΗΣ ΧΡΗΜΑΤΟΔΟΤΗΣΗΣ ΤΗΣ ΤΡΟΜΟΚΡΑΤΙΑΣ on 9 February 2018.
EMA letter to Greece on 4MLD Read More »
The EMA responded to the EBA Consultation EBA-CP-2017-16 on Draft Regulatory Technical Standards on cooperation between competent authorities in the home and host Member States in the supervision of payment institutions operating on a cross-border basis under Art. 29 (6) of PSD2 on 5 January 2018.
EMA response to EBA consultation on home host cooperation under PSD2 Read More »
The EMA responded to the EBA Consultation EBA-CP-2017-13 on “Draft Guidelines on the fraud reporting requirements under Article 96 (6) of Directive (EU) 2015/2366 (PSD2)“ on 3 November 2017.
EMA response to EBA Consultation on fraud reporting requirements Read More »
