PSD 3 AND PSR: What is new for the PI authorisation phase?

On 28 June 2023, the European Commission published the proposals for the legislative package on payment services (“Revised Payments Legislative Package”) that will replace the Directive (EU) 2015/2366 on payment services in the internal market and Directive 2009/110/EC on the taking up, pursuit and prudential supervision of the business of electronic money institutions and merge the legal frameworks applicable to payments and electronic money services.

Awaited with great interest by all stakeholders, the European Commission’s initiative considers the outcome of the consultation carried out in 2022, including the European Banking Authority’s advice on the review of PSD2, and the study on the application and impact of PSD2, and aims to tackle the shortcomings / challenges identified in the existing payments legal framework, while improving consumer protection, competition, security, and innovation in the EU payments landscape.

In our note we aim to outline the main changes proposed by the Revised Payments Legislative Package that have an impact on the authorization phase, including requirements on / content of the authorization application, qualification of payment services and scope of licensing requirements.

📰You can read our notes in full here or here.

Authors: Simona Petrișor – Partner and Alexandru Achim – Managing Associate Bondoc & Asociații