Legal regulations

In the coming months, part of the activities currently carried out by electronic money institutions (EMIs) will need to be reclassified from e-money issuance to payment services. This change will have very practical implications for capital requirements, client agreements, relationships with e-money distributors, and internal processes. In Case C-661/22, the Court of Justice of the European Union significantly narrowed the concept of "electronic money". As a result, the holdi

Even though the PSR aims to harmonise the regulation governing payment services provision across the EU, some room for manoeuvre remains for national competent authorities regarding administrative sanctions and measures. Member States must lay down rules on administrative sanctions and measures applicable to infringements and ensure they are implemented. Sanctions must be effective, proportionate and dissuasive. The PSR reduces Member States’ discretion for key infringements:

The rules must be followed not only by regulated entities The Payment Services Regulation (PSR) applies to services provided with the EU by PSPs. In addition, the PSR also applies to services provided within the EU by these entities: Technical services providers Operators of payments systems and payment schemes E-communication services providers Hosting services providers Providers of very large online platforms and of very large online search engines Original equipment manuf

SCA: two inherence elements may be allowed PSD3/PSR keeps the core SCA framework largely unchanged. SCA must still be based on two or more independent elements: knowledge, possession and inherence. The general rule remains: at least two elements should come from different categories. However, PSD3 introduces an exception: two elements from the inherence category may be used, provided this does not reduce the overall level of security. SCA: no major change in scope PSR keeps t

Real-time mandatory Verification of Payee (VoP) – central fraud prevention tool PSPs must provide real-time verification of the payee before the payer authorises a credit transfer. This verification is based on the payee’s name and unique identifier, such as an IBAN. If there is a discrepancy between the payee’s name and the unique identifier, the PSP must immediately alert the payer before the transfer is authorised. ❗Under the PSR proposal, VoP would also cover credit trans

Agreed final text of payments package (3rd Payment Services Directive (“PSD3”) and the Payment Service Regulations (“PSR”) was published on 23rd April 2026 and awaits final approval. Overview Regulatory frameworks on payment services and e-money will be blended into one single regulatory framework. PSD2 and EMD2 will be replaced by PSD3 and PSR, the very first payment services regulation. PSD3 will need to be transposed into national laws regulating payment services. SR will

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