The European Banking Authority has published a consultation paper (CP) and some draft regulatory technical standards (RTS) on the separation of payment card schemes and processing entities, under article 7(6) of the Interchange Fees Regulation (IFR). The consultation runs until 8 March 2016, and responses must be submitted using the “send your comments” button that’s available here.

If made in their draft form, the RTS will require payment card schemes and processing entities to have:

  • accounting processes in place, that enable them to produce annual audited information related to separated balance sheets., and separate profit and loss accounts;
  • separate work spaces; and
  • independent senior management, management bodies and staff.

Our Client Alert summarizes the effect of the IFR, which came into force on, and has applied to all relevant entities since, 8 June 2015.

The CP provides some clarity on supervisory expectations during the period between the application date for article 7 of the IFR (8 June 2016), and the possible later application of the RTS.