The European Commission (‘EC’) published a proposal for a revised Payment Services Directive (‘PSD2’) in July 2013. PSD2 is a maximum harmonisation directive and will repeal and replace the first Payment Services Directive that was adopted in 2007 (‘PSD’). PSD2 will be required to be transposed by Member States within two years of the date it comes into force.
PSD2 presents technical and regulatory challenges. I would strongly encourage regulated and unregulated firms operating in the payments industry to engage early in the process. Firms should review their business models against the new rules to ascertain whether any change programmes need to be implemented and/or IR infrastructure investments will be required in order to ensure timely compliance with the new rules.
‘A practical guide to PSD2 for firms operating in the payments industry’ was originally published in April 2015 for E-Finance & Payments Law & Policy (subscription required).