News & Analysis as of

Payment Services Directive

A&O Shearman

PSR consults on the revocation of SD4

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The UK Payment Systems Regulator (PSR) has published consultation paper CP25/2 alongside a new webpage, proposing the revocation of Specific Direction 4 (SD4) and its amendment, SD4a. SD4, introduced following the PSR's 2016...more

A&O Shearman

FCA findings on risk and wind-down planning in payment and e-money firms

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The UK Financial Conduct Authority (FCA) has published the findings of its multi-firm review into risk management and wind-down planning across e-money and payment firms. While the FCA had observed examples of good practice...more

A&O Shearman

HMT updates BNPL policy for domestic premises suppliers

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HM Treasury has published a policy paper setting out an update to its final position to its 2024 consultation on regulating Buy-Now, Pay-Later (BNPL) products which led to the laying of the draft secondary legislation, The...more

McDermott Will & Emery

Barrierefreiheitsstärkungsgesetz (BFSG) und die betroffenen Bankdienstleistungen

McDermott Will & Emery on

Am 28. Juni 2025 tritt das Barrierefreiheitsstärkungsgesetz (BFSG) in Kraft. Das Kernziel des BFSG ist es, allen Menschen die barrierefreie Teilhabe am Wirtschaftsleben zu ermöglichen. So ist die Teilhabe an digitalen...more

A&O Shearman

The Payment Services and Payment Accounts (Contract Termination) (Amendment) Regulations 2025

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The Payment Services and Payment Accounts (Contract Termination) (Amendment) Regulations 2025 (SI 2025/688) have been published, alongside an explanatory memorandum. The regulations amend regulation 51 of the Payment Services...more

A&O Shearman

FATF updates standards on payment transparency

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The Financial Action Task Force (FATF) has published revised standards and an accompanying explanatory note, updating its comprehensive framework on recommendations to strengthen global efforts in anti-money laundering,...more

A&O Shearman

ECB Decision (EU) 2025/1148 on access by Non-Bank Payment Service Providers to TARGET published in OJ

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The Decision (EU) 2025/1148 of the European Central Bank (ECB) adopted on 2 June, has been published in the Official Journal of the European Union. This decision amends Decision (EU) 2025/222 concerning access by non-bank...more

Latham & Watkins LLP

EBA Publishes No Action Letter on Interaction Between MiCA and PSD2

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In the short term, firms are likely to face dual authorisation and significant regulatory requirements. On 10 June 2025, the European Banking Authority (EBA) issued a No Action letter on the relationship between the...more

A&O Shearman

EBA opinion on PSD2 and MiCAR

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The European Banking Authority (EBA) has issued an opinion (referred to as the No Action letter) in response to a request from the European Commission (EC) in December 2024, on the interplay between Payment Services Directive...more

A&O Shearman

ECB consults on extension to T2 operating hours

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The European Central Bank (ECB) has published a consultation paper (CP) exploring the extension of operating hours for its real-time gross settlement (RTGS) system, T2. This involves both its daily operational hours and its...more

McDermott Will & Emery

Anzeigen digital – BaFin ermöglicht zukünftig digitale Anzeigen zu Geldwäschebeauftragten

McDermott Will & Emery on

Die Bundesanstalt für Finanzdienstleistungsaufsicht (BaFin) öffnet ihr Portal der Melde- und Veröffentlichungsplattform (MVP-Portal) zukünftig auch für geldwäscherechtliche Anzeigen. Konkret betrifft dies alle im Voraus...more

A&O Shearman

UK Government advances BNPL Regulation

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HM Treasury (HMT) has published a response to its 2024 consultation on regulating Buy-Now, Pay-Later (BNPL) products and laid the draft secondary legislation (Financial Services and Markets Act 2000 (Regulated Activities etc)...more

A&O Shearman

Amendment to the TARGET Guideline postponed

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The European Central Bank (ECB) has announced that the amendment to the TARGET Guideline, which would allow non-bank payment service providers (non-bank PSPs) to participate in TARGET is postponed... ...more

A&O Shearman

PSR update on impact of APP fraud reimbursement scheme

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The UK Payment Systems Regulator (PSR) has published an update on what it has seen since the implementation of its authorised push payment (APP) fraud reimbursement scheme in October 2024. The data covers UK payments made via...more

A&O Shearman

BoE speech on the digitalisation of money and assets: proposed stablecoin regulatory framework

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The Bank of England (BoE) has published a speech by Sarah Breeden, Deputy Governor for Financial Stability, at the Point Zero Forum. The subject of the speech was the digitalisation of money and assets, and in particular the...more

A&O Shearman

IOSCO – CPMI report assessing EU implementation of Principles for Financial Market Infrastructures

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The International Organization of Securities Commissions (IOSCO) and the Committee on Payments and Market Infrastructures (CPMI) has published a report, alongside a press release, evaluating the EU's implementation of the...more

A&O Shearman

HMT announces new rules for bank account closures and payment service terminations

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The HM Treasury (HMT) has published a draft statutory instrument introducing new rules requiring banks and payment service providers (PSPs) to give customers at least 90 days' notice before closing their account or...more

A&O Shearman

FCA findings on international payment pricing transparency

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The UK Financial Conduct Authority (FCA) has published examples of good and poor practices following its review into international payment pricing transparency. Under the consumer duty, in line with the FCA's Handbook (PRIN...more

A&O Shearman

UK 2025 Regulatory Initiatives Grid published

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The Financial Services Regulatory Initiatives Forum (the Forum) has published the Regulatory Initiatives Forum Grid (the Grid), with the UK Financial Conduct Authority (FCA) also updating its webpage. The previous Grid was...more

A&O Shearman

New FCA work programme for 2025/26

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The UK Financial Conduct Authority (FCA) has published its work programme for 2025/26, alongside a press release summarising its approach to supporting the testing of innovative products and new firms. The work programme sets...more

A&O Shearman

BoE response to discussion paper on reviewing access to RTGS accounts for settlement

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On 8 April, the Bank of England (BoE) has published its response to the discussion paper on reviewing access to Real-Time Gross Settlement (RTGS) accounts for settlement. In the discussion paper, initially published on 8...more

A&O Shearman

UK PSR consults on remedies following market review of card scheme and processing fees

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The UK Payment Systems Regulator (PSR) has published its consultation CP25/1 on potential remedies to address findings following the PSR's final report (published on 6 March) on its review of card schemes and processing fees....more

A&O Shearman

Regulatory monitoring - March 2025

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1. Bank regulation - 1.1 PRUDENTIAL REGULATION - a) General - (i) EU - EBA: Updated methodology on the regulatory and supervisory equivalence of non-EU countries - Status: Final - The EBA has published its updated...more

A&O Shearman

Regulatory monitoring: EU version Newsletter - March 2025

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1. Bank regulation - 1.1 PRUDENTIAL REGULATION - a) General (i) EU - EBA: Updated methodology on the regulatory and supervisory equivalence of non-EU countries - Status: Final - The EBA has published its updated...more

A&O Shearman

FSB letter to G20 finance ministers and central bank governors ahead of meeting

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The Financial Action Task Force (FATF) has published a second consultation on payment transparency, and in particular proposed revisions to recommendation 16 (R.16). The revisions adapt the FATF Standards to the changes in...more

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