A case currently before the European Court of Justice (ECJ) has the potential to significantly influence the interpretation of payment services regulation in the EU. Manuel Campos Sánchez-Bordona, advocate general of the ECJ,...more
On 12 February 2026, the European Banking Authority (“EBA”) issued an Opinion advising national competent authorities (“NCAs”) on actions to take once the transition period set in the EBA No Action Letter of 2 June 2025...more
The European Banking Authority (EBA) has issued an opinion advising national competent authorities (NCAs) on how to proceed when the transition period (under its no-action letter of 2 June 2025) ends on 2 March. This...more
In accordance with a 12 February European Banking Authority opinion, as of 2 March 2026 electronic money token transactions that qualify as payment services must be fully compliant with PSD2, otherwise they will be subject to...more
The European Banking Authority (EBA) has published a follow-up peer review report on the authorisation of payment institutions (PIs) and electronic money institutions (EMIs) under the revised Payment Services Directive...more
Introduction - The Second Payments Services Directive ((EU) 2015/2366) (“PSD2”) provided payment service users with access to their payment data by mandating that payment service providers grant “read” and (limited)...more
The ECJ has confirmed that a payment service user (PSU) is deprived of the right to reimbursement for an unauthorised transaction under PSD1 if: they fail to notify without undue delay upon becoming aware of it; or...more
The EBA has set out its opinion on the interplay between MiCA and PSD2 in relation to crypto-asset service providers (CASPs) that transact with electronic money tokens (i.e. a category of stablecoins under MiCA). The EBA...more
The UK’s consultation on deregulating commercial agents could have knock-on impacts on payment services and create regulatory divergence from the EU....more
Crypto-asset firms are increasingly focused on the impact of MiCA on their businesses both from the perspective of high-level strategy and in relation to changes to their day-to-day compliance arrangements. MiCA represents a...more
On 23 April 2024, the European Parliament announced its adoption at first reading of amended texts of the European Commission’s June 2023 legislative proposals for a Directive on payment services and electronic money services...more
“Super Wednesday” 28 June 2023 marked the beginning of the next phase in the evolution of EU payments regulation with the European Commission’s publication of its anticipated proposals to improve the functioning of PSD2. This...more
HM Treasury has published a review and call for evidence on the Payment Services Regulations 2017, as well as the outcome of a post-implementation review of the Payment Card Interchange Fee Regulations 2015. Both...more
Consumers and service providers should take note of some of the enhanced risks upon an e-money institution’s insolvency. Technology is rapidly changing the way customers and businesses interact with financial systems....more
Key developments of interest over the last month include: Queen's Speech 2022 announces forthcoming Financial Services and Markets Bill; European Commission consultations and calls for evidence on PSD2 review and open...more
There has been a recent flurry of EU developments relating to a number of ongoing initiatives relevant to firms in the retail banking and payments sectors, including some movement on the European Commission's review of PSD2...more
Key developments of interest over the last month include: In this Newsletter: For previous editions of the Global Payments Newsletter, please visit our Financial Services practice page. On 9 March 2022, President Biden signed...more
The European Banking Authority is consulting on draft Regulatory Technical Standards to amend the existing RTS on strong customer authentication and common and secure open standards of communication under the EU Payment...more
Key developments of interest over the last month include: Europe: EBA consults on proposed guidelines on limited network exclusion under PSD2 UAE: Central bank issues Retail Payment Services and Card Schemes Regulation United...more
PSD2: EBA consults on guidelines on limited network exclusion The European Banking Authority (EBA) is consulting on guidelines on the limited network exclusion (LNE) under the revised Payment Services Directive (PSD2)....more
On 1 July 2021, the Bank of Italy transposed into the Italian legal framework Article 106 of PSD2 regarding the obligation for payment service providers to inform consumers of their rights in the context of the provision of...more
Key developments of interest over the last month include: Hong Kong: FSTB publishes consultation conclusions on virtual asset services providers licensing regime Europe: European Commission publishes proposal for Regulation...more
The paper identifies potential gaps in protections for consumers, with a focus on consumer-to-business payments via the Faster Payments System. In November, Pay.UK, the retail payments authority, released a summary paper...more
Payment Services and Electronic Money (Amendment) Regulations 2020 published - The Payment Services and Electronic Money (Amendment) Regulations 2020 (SI 2020/1275) have been published, together with an explanatory...more