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Implementing the payment services directive

Context and aims of PSD:

  • European Commission seeks to harmonise the fragmented nature of the national payment infrastructures and their supporting laws
  • The PSD is one additional step in the EU’s effort to achieve a single payments market
  • The PSD aims at increasing consumer protection and market transparency and at enhancing competition in payment markets by removing market entry barriers
  • The PSD applies to payment services provided within the EU (27 Member States) and 3 EEA countries (Iceland, Liechtenstein, Norway)

The PSD is a key part of the move towards SEPA -compliance is mandatory by November 1st, 2009.

The Directive applies to payment services made in Euro or in the currency of a Member State outside the Euro area:

  • 11 currencies as well as the Euro are concerned
  • 27 countries of the EU are in scope
  • In addition to the 27 countries, three EEA countries (Iceland, Liechtenstein, Norway) will transpose the PSD in their national legislation
  • All payments made within the PSD area in one of the currencies of this area should be PSD compliant

PSD impacts clients, payment services, payment services institutions and transactions with third parties based within PSD area or outside PSD area.

On a practical level, PSD will directly impact users, payment service providers and payment services as detailed in the provisions of the Directive, but will also impact all the related processes, systems, organisation and revenues.

Based on our experience with large regulatory programmes, we recognise the importance of developing a strong governance framework which is fundamental to mitigate delivery risk. A detailed impact analysis should be used to define this framework.

Being a multidisciplinary firm, we can assist you on all dimensions of the PSD project.

PSD is neither a pure compliance, nor a pure technology project. At first work will focus on gap analysis, defining new and updating existing policies, upgrading client agreements and take on process. It might then expand to IT projects related to payment services and client systems, data storage or infrastructure.

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