European Payment Institutions Federation (EPIF)

EPIF strongly supports the content of this joint industry letter on access by non-bank payment services providers to central bank accounts.   EU legislation has opened the way for this direct access. With this comes the possibility to offer instant account-based payments to customers. In the future, this opens up the possibility for EPIF members to offer digital euro wallets. Importantly, it allows EPIF members to safeguard client funds in central bank accounts.   We understand that access to central bank accounts comes with a price. Interested non-bank payment providers will need to meet the appropriate security and risk management standards to maintain the integrity of the intra-bank payment system. The licensing and supervision of our sector has been set by EU laws. These are currently being further reviewed. While security and risk management standards are important they should not become a barrier to making access to central banks a reality.   European customers deserve choice, competition and innovation in the payment sector. A big thank you to EU legislators for having recognized this.

EPIF is delighted to have responded to the AI in financial services consultation by DG FISMA (https://lnkd.in/e3Dx3G8b).   Our members are at the forefront of developing and rolling out new technologies. AI is no exception and already being employed in a wide range of use cases especially in fighting fraud and money laundering.   EPIF believes this power of risk mitigation should be fully recognized when it comes to the application of a risk-based approach to regulatory compliance.   We all need to do our bit to fight illegal activity but we should do so in a smart way that doers not create extra barriers in the daily life of millions of citizens. This is where AI can really help.   Therefore it is good that DG FISMA is now studying this issue. Thank you!

The Working Group of the Euro Retail Payments Board (#ERPB) of which #EPIF is a member has published its Report from the ERPB Working Group on fraud prevention (https://lnkd.in/eA6uv3iH) This initiative underscores the need for all actors in the fraud chain to collaborate more efficiently in preventing and combating fraud.   The report identifies four “gamechangers” that are necessary to strengthen the fraud prevention and mitigation across Europe, as well as a set of best practices identified to combat fraud.    These are:   1) Effective cross-sectoral collaboration beyond the payment industry and shared responsibilities; 2) The sharing of fraud insights and data; 3) A supervisory enforcement and cooperation at EU level across sectors beyond the payment industry; 4) Ensuring that product design prioritises consumer protection.    Thanks to Mafalda Moz Teixeira who represented EPIF on this Group.

European payment service providers (PSPs) are committed to combating #payment #fraud and enhancing transaction security across Europe. EPIF is delighted to share with you its views on the subjective approach to the #authorization of payment transactions and the current concerns of the industry with this approach, notably in terms of the increase dispute risks, the operation challenges and impact on security protocols.   With this in mind, EPIF proposes a three-step recommendation: • Maintain objective authorization criteria;  • Revert the burden of proof post-SCA; and  • Standardize the definitions of gross negligence. Our more detailed views are further explained in the statement below.

EPIF is delighted to share with you its views on #fraud under the PSR and its proposal for a more comprehensive fraud prevention approach. Fraud is a societal risk that jeopardizes the safe functioning of the digital economy. To properly tackle fraud, it is necessary to implement a wide range of tools that allow all the actors in the fraud chain to have the appropriate means to act, both together and individually, based on where they sit in this chain. This includes payment service providers, telecom operators and operators of online platforms. These solutions should emphasize cross-sectoral collaboration, cooperation and education to empower consumers. Given the ramifications fraud and scams can have for society, going well beyond the remit of payments or financial services, EPIF calls on the European Commission to set up a cross-sectoral task force to draft a holistic ‘consumer anti-fraud and scam strategy’. This would bring together DG FISMA, DG CONNECT, DG HOME and DG JUST as well as experts from all relevant sectors including the financial sector, the telecommunication sector, online platforms, civil society consumer groups and law enforcement agencies. You can find our full position below.

The European Parliament plenary adopted the draft report on the Payment Services Directive (PSD3) and the Payment Services Regulation (PSR). EPIF welcomes this vote and is happy to see the prioritization given to the payments package by the European Parliament. The PSD3/PSR will bring significant improvements to the current framework and the European Parliament’s position reinforces important aspects around consumer and data protection, open banking and the swift implementation of the merger between the PSD2 and the E-Money Directive (EMD2). EPIF would like to see some improvements with regards to fraud prevention, strong customer authentication (SCA) and allocation of liability that could further enhance legal clarity in the text. This vote is however an important step. EPIF will continue to closely follow the developments on the payments package and monitor its impact on payment markets.  

The European Parliament’s Economic and Monetary Affairs draft report on the Financial Data Access proposal (#FiDA) was adopted today. EPIF is pleased to see that significant improvements are brought to the proposal, notably on the set up and development of financial data access schemes, requirements for common standards and technical interfaces and on the interplay of FiDA with other legislations. EPIF would however still see a benefit in having a staged-approach based on use cases for the implementation of the proposal and remains concerned with the exclusion of designated gatekeepers from being eligible to become a Financial Information Service Provider. EPIF will continue to closely follow the developments on the file and monitor its impact and potential opportunities for the payments market.  

EPIF is delighted to share with you the joint statement co-signed with other industry representatives to highlight a common concern with the treatment of merchant initiated transactions (MITs) within the proposal for a #payments services regulation (#PSR). The new proposal extends the unconditional refund rights under Article 62(1) that exists for direct debits to all other MIT transactions. This implies that payers would be able to request a “no questions asked” refund from payment service providers (PSPs) within eight weeks of any MIT. We would encourage co-legislators to consider removing this obligation for unconditional refund rights for MITs, with the exception of direct debits. You can find below our joint industry letter which explains this issue in more detail.

EPIF, together with other EU Associations, continues to call on co-legislators to reconsider the proposed rules for exempting certain low-value, low-risk e-money products from the requirements under the #AML Regulation. Both consumers and retailers greatly benefit from the current e-money exemption under the 5th AML Directive which should thus be maintained in the AMLR. In particular, we recommend co-legislators to: ➔ Support the e-money exemption in Article 15 (3) per the EP’s proposed text ➔ Remove the restriction to "a single Member State" ➔ Remove the reference to a "direct commercial agreement with a professional issuer" ➔ Support Article 22 (1) (c) in the EP’s proposed text The full Joint Call for Action can be found on the EPIF website: https://lnkd.in/d2CqF5jh

Our last panel of the day has just finished. Thank you to Marcus Härtel, Julia Kowalski, Ninja Reggelin and Hartwig Gerhartinger for an insightful discussion on the Digital Euro. We were delighted to hear the European Central Bank’s views on the key elements of the Digital Euro and the next steps of the new phase of the project. EPIF is following closely the technical and legislative developments of Digital Euro and is committed to continue the discussions for delivering a Digital Euro that brings as much value as possible to citizens, businesses and public authorities.