The European Union is in the process of updating its regulatory regime for payment services to reflect the developing nature of the payment services market. The European Commission's proposed revised Payment Services Directive ("PSD2") will cover a wide range of payments-related services and businesses. But questions remain about the scope and effect of the European regulatory regime that PSD2 does not fully answer.

This Alert discusses the most recent changes in the EU's proposals, and explains the key differences between PSD2 and the current EU payment services regime.