On 19 December 2017, the ACM published a more specific study on the position of fintechs in the payment services system. Banks have information that fintechs require in order to be able to offer their services. One of the ACM’s conclusions is that there is a genuine risk of foreclosure of these new providers. The ACM distinguishes between front-end and end-to-end fintechs. Front-end fintech companies offer payment initiation and/or account information services. The input required by these companies consists of account information from a customer with a specific bank. According to the ACM, this means that banks may have a dominant position with regard to this type of information. Since banks (potentially) compete with front-end fintechs, the ACM sees a genuine risk that these companies will be excluded.

End-to-end fintech companies offer payment solutions (such as Paypal and Afterpay). In order to be able to provide these services, they need to obtain access to systems for clearing and settlement. They can obtain such access indirectly by opening a payment account with a bank. The ACM observes that, in view of the number of providers, it is unlikely that there is market power of banks when issuing payment accounts. Nevertheless, the ACM notes that it will closely monitor that the provisions in the PSD2 Directive that ensure access to payment accounts for end-to-end providers are adhered to.