Brussels, July 25, 2022: ETPPA publishes response to second ERPB technical session on a digital euro
We are reiterating our suggestion to maintain the scope of current central bank money (coins and notes) and its current uses cases (offline peer-to-peer and in-store payments) and design the D€ distribution model accordingly. Creating a payments scheme, as now suggested by the ECB, would create a very real risk of crowding out the private sector financial industry.
Click here to view ETPPA's feedback.
Brussels, July 5, 2022: ETPPA publishes response to European Commission's PSD2 consultation
ETPPA has published its response to the European Commission's targeted consultation on the review of PSD2.
Whilst PSD2 was meant to foster innovation, competition and security in the EU's payment services landscape, the outcome to date depends heavily on the country being looked at. Where banking was rather closed before, e.g. UK, France and Southern Europe, PSD2 has played an important role in removing some barriers to innovation in retail payments and fostering competition, although it has not been as impactful as was originally intended. Where banking was already quite open beforehand, e.g. Germany, Austria, Nordics, we see a big step backwards.
ETPPA looks forward to a positive review of PSD2 for the benefit of consumers so that the original spirit of PSD2 may be fully recognised.
Click here to view ETPPA's feedback and here to see our position paper on the PSD2 review.
Brussels, July 5, 2022: ETPPA publishes response to European Commission's Open Finance consultation
ETPPA has published its response to the European Commission's targeted consultation on Open Finance framework and data sharing in the financial sector.
ETPPA believes that Open Finance should enable a complete unbundling of financial data-based value-added services from the actual holder of the data, which allows the Data Owner not just to switch provider, but more importantly leave their data wherever it is, and still get access to the full market of financial products offered by any other provider based on their own data.
Europe's Open Finance Framework should not mislead the public by referring to “data sharing” and instead establish trust by making it very clear that it ensures the ongoing confidentiality of data and no change in ownership or control.
Click here to view ETPPA's feedback.
Brussels, June 13, 2022: ETPPA publishes response to European Commission's Digital euro consultation
ETPPA has published its response to the European Commission's targeted consultation on a digital euro.
ETPPA believes that a central bank issued Digital Euro should complement or replace existing central bank money, rather than getting into competition with private digital money, e.g. that of commercial banks or e-money institutions. Therefore, it should replicate the characteristics of cash (offline tokens in a wallet) as closely as possible and stay away from the characteristics of existing digital money (online accounts) as much as possible. Anything else would go against the intention to avoid the crowding out of the existing financial services market, and most importantly, would hardly be understood by the public and not meet their needs.
Click here to view ETPPA's feedback.
Brussels, May 26, 2022: ETPPA publishes response to first ERPB technical session on a digital euro
Following ETPPA's participation in the first Euro Retail Payments Board (ERPB) technical session on a digital euro, held on 4 May, ETPPA has published its written feedback submitted to the ERPB. As an active member of the ERPB, ETPPA very much welcomes the opportunity to provide input on behalf of TPP's to the ERPB's work on the digital euro project and remains ready to provide further input as the ERPB's work here progresses further. We are suggesting to replicate the characteristics of cash (offline tokens in a wallet) as closely as possible and stay away from the characteristics of existing digital money (online accounts) as much as possible.
Click here to view ETPPA's feedback.
Brussels, May 2, 2022: ETPPA publishes their Position on Instant Payments Key Features
Following our ETPPA Position on Instant Payments published in June last year and Commissioner McGuinness’ confirmation in the meantime that the related legislation will be proposed this year, this additional position paper re-iterates the key features required for Instant Payments from our perspective and provides further detail, particularly in relation to retail payments.
Click here to view this position paper.
Brussels, January 31, 2022: Payments Industry calls again upon EDPB to address remaining issues and risk of fragmentation
Following a previous letter sent on 27-Oct-2020 highlighting our concerns about the Guidelines on the interplay of PSD2 with the General Data Protection Regulation (GDPR), the payments sector has sent another joint letter to the relevant authorities, stressing the still remaining issues and the risk that national Data Protection Authorities (DPAs) could start taking a fragmented approach to the interpretation of the provisions.
Click here to view the new joint letter.
Brussels, January 26, 2022: ETPPA enters new phase of collaboration with the European Digital Finance Association (EDFA)
In a move to further advance TTP and startup interests in the field of open finance, PSD2 and beyond the ETPPA and EDFA have signed a memorandum of understanding laying out both parties' commitment to working together. This collaboration will further strengthen both ETPPA and EDFA in their missions to support Europe’s global role in the financial technology sector.
Click here to view our statement.
Brussels, November 29, 2021: ETPPA summary position on the European Commission's AML package
ETPPA proposes that AISPs and PISPs should be excluded from the AML Regulation and should instead be subject to a more limited range of AML/CFT rules, which govern primarily the investigation of suspicious transactions. There is a consensus among regulators that the use of Account Information Services (“AIS”) and payment initiation services ("PIS") does not increase the risk of money laundering or terrorist financing to any significant extent.
Click here to view our summary AML position paper.
Brussels, November 25, 2021: ETPPA responds to EBA 90-day re-auth SCA consultation
ETPPA very much welcomes this consultation about amending the 90-day re-authentication SCA exemption, which we have lobbied for more than 4 years, since the very first draft version of this RTS. Our response principally supports the EBA proposal, which will be a big step forward over the status quo and is urgently needed. To make this step even bigger, we are suggesting additional interpretations and amendments, which in our view are within the current scope of PSD2, and therefore possible well before the envisaged review of PSD2.
Click here to view our response.
Brussels, November 22, 2021: ETPPA strongly encouraged by the words of Commissioner Mairead McGuinness in her speech on Instant Payments
ETPPA welcomes the very positive words of Commissioner Mairead McGuinness, during a Nov. 16 speech (video) on the importance of Instant Payments rollout in the EU. We believe there is a clear need for swift legislation here in order to help payment initiation service providers and fintechs leverage the huge investments already made into PSD2 infrastructure.
Click here to view the statement.
Brussels, November 05, 2021: ETPPA publishes position paper on the European Commission’s AML package
ETPPA believes that additional amendments and clarifications are necessary, specifically in the AML Regulation, to ensure that third party providers are afforded a fair environment for competing with other payment options and payment service providers, in particular card-based payments. To that end, the ETPPA proposes that AISPs and PISPs should be excluded from the AML Regulation and should instead be subject to a more limited range of AML/CFT rules, which govern primarily the investigation of suspicious transactions.
Click here to view the position paper.
Brussels, September 30, 2021: ETPPA response to the BaFin API exemption consultation
BaFin has been a positive role model in seeking dialogue with the industry, hearing the concerns of TPPs and scrutinising the functionality of the dedicated API interfaces. ETPPA welcomes the draft notes that set out important legal criteria that such interfaces need to fulfil, but suggests additional considerations to avoid any premature API exemptions, which could lead to TPP services getting foreclosed from the market and competition being obstructed.
Click here to view the response.
Brussels, September 21, 2021: ETPPA appoints Padraig Nolan as new COO
To grow and solidify ETPPA’s influence in the EU, the board has today appointed Padraig Nolan as their new Chief Operating Officer. Padraig, a Brussels insider, has advised some of the top global financial institutions over the years with a strong focus on payment services and fintech. He holds a LL.M in European law and is a certified information privacy professional.
Click here to view the press release.
Brussels, June 18, 2021: ETPPA publishes position paper about Instant Payments
Instant Payments are essential for new or improved European Retail Payment solutions able to compete with the cards and wallets from the East and West. SCT Inst will give payers an additional payment instrument, which is less costly than handling cash and more available and cheaper than cards. Mandating SCT Inst is the only option, which can lead to its adoption in the time and with the reach required for the European retail payments market to catch up and get ahead.
Click here to view the position paper.
Brussels, June 10, 2021: ETPPA presenting PIS@POS at EC Instant Payments webinar
ETPPA chair Ralf Ohlhausen presented the potential for Payment Initiation Services at retail, in-store Point of Sales (POS) terminals, which was on the agenda of the European Commission's “Exploring the potential of instant payments for EU consumers and businesses” webinar. The event was recorded with the PIS@POS presentation starting at 12:11.
Click here to view the slides.
Brussels, June 07, 2021: ETPPA co-signs Open Letter to the UK CMA
ETPPA joins other representatives of the UK open banking ecosystem in writing an open letter to the UK's Competition and Market Authority (CMA) Board, expressing concern about the future of the UK Open Banking Implementation Entity and the current CMA consultation on the matter.
Click here to view the letter.
Brussels, April 30, 2021: ETPPA response to the UK FCA SCA-RTS consultation
ETPPA strongly supports the need for amendments to the RTS on SCA & CSC and welcomes the suggestions of the UK regulator, although we recommend some essential amendments and also a number of additional changes. We sincerely hope that the rest of Europe will also see an RTS2 very soon to not fall behind!
Click here to view our response.
Brussels, April 7, 2021: ETPPA feedback on the Initiative on instant payments in the EU
ETPPA fully agrees that instant payments shall become the new normal and also to the EC’s Retail Payments Strategy supporting this objective. We recommend legislative action to mandate the adherence to SCT Inst for all current and future adherents of SCT and as a minimum, the subset of these servicing consumer (retail) payment accounts.
Click here to view our feedback.
Brussels, March 5, 2021: ETPPA and Open Banking Europe agree Mutual Cooperation Agreement
ETPPA's cooperation with Open Banking Europe (OBE) over the past few years has been very fruitful already and with this agreement we are strengthening this further given the many outstanding issues around Open Banking and the need for applying the lessons learned to Open Finance.
Click here to view our response.
Brussels, February 26, 2021: ETPPA change requests to the EPC's SEPA Request-to-Pay (SRTP) Scheme
ETPPA suggests to increase the relevance of SRTP to PSD2-licensed TPPs, and in particular PISPs, by enabling the “Payer RTP Service Provider” role for “classical PISPs”, which typically do not have any ongoing relationship with payers, because they usually act as a one-off payment facilitator.
Click here to view our change requests.
Brussels, January 12, 2021: ETPPA response to the ECB's Digital Euro consultation
ETPPA welcomes the prospects of a Digital Euro and strongly supports its introduction. TPPs are amongst the best placed contenders in leveraging and promoting the new opportunities enabled by Central Bank Digital Currencies. Unencumbered by defending the distribution of commercial bank money, we are looking forward to increased competition and to introduce new value-added services in relation to any type of Digital Euro solution. We have a strong preference for a predominantly account-based design, but cash-like privacy should also be enabled up to AML-regulated thresholds.
Click here to view our response.
Brussels, December 10, 2020: Director Operations
ETPPA is looking for a dynamic and experienced individual to take the role of Director Operations, that can help develop the new association and represent the interests of its growing membership in the discussions on a European and national level in relation to the implementation and evolution of the PSD2 and its RTS, with the objective of creating a well-performing and integrated landscape for TPPs across Europe.
Click here to view the function description.
Brussels, October 27, 2020: Payments Industry calls upon EDPB to revise their PSD2/GDPR interplay guidelines
ETPPA joined forces with other European payment industry associations in sending a letter to the European Data Protection Board (EDPB) emphasizing and jointly reiterating common concerns regarding the EDPB Guidelines on the interplay between PSD2 and GDPR. This follows ETPPA’s individual response to the EDPB’s consultation, where we already explained the main issues and requested the redrafting of these guidelines. Today's letter, co-signed by ESBG, EBF, EACP, ETPPA, EPIF, EAPB, PE, EFA, and EMA, clearly demonstrates that it is not just TPPs, but the whole payments industry, which would be negatively impacted.
Click here to view the joint letter.
Brussels, October 2, 2020: ETPPA response to the EC eIDAS/EUid consultation
ETPPA believes the EU should focus on the provision of an interoperability standards framework/scheme that would also allow other public and private sector organisations to participate. Some participants will issue eID credentials, for example within their own smartphone apps. Other participants will take advantage of these eID credentials (Federated Identity) within their own services, e.g. for providing Strong Customer Authentication (SCA).
Click here to view our response.
Brussels, September 16, 2020: ETPPA response to the EDPB guidelines on the interplay of PSD2 and GDPR consultation
ETPPA would welcome the redrafting of the guidelines based on the input of a more balanced representation of all relevant stakeholders including TPPs. Many are based on wrong assumptions and therefore incorrect or not applicable. It is very surprising that the focus of these guidelines is on TPPs, rather than all PSPs acting under PSD2. Applying the proposed guidelines to ASPSPs and their processing of personal data would make banking and payments impossible.
Click here to view our response.
Brussels, August 27, 2020: ETPPA feedback to EPC consultation on SEPA Request-to-Pay (SRTP)
The EPC’s so-called SEPA Request-to-Pay rulebook deviates from the ERPB recommendation by proposing solely a 4-corner model suitable only for a bank-centric and interchange-enabling scheme. We strongly recommend to rather follow an Open RTP approach, which uses and expands the Open Banking/PSD2 framework, rather than developing a separate independent scheme, which starts from scratch, duplicates all efforts and is likely to create unlevel playing fields between banks and bank-independent PSPs and SPs in the payments ecosystem.
Click here to view our feedback.
Brussels, August 26, 2020: ETPPA feedback to EC consultation on the AML Action Plan
ETPPA responded to the EU Commission consultation on the AML Action Plan. ETPPA favours and would welcome a harmonisation of AML rules at an EU level in targeted areas, combined with the effective application of a risk based approach. It questions, however, the need to include Third Party Providers into the scope of the AML rules due to recognised low risk in particular in relation Account Information Service Providers (AISPs), as they do not conduct financial activities.
Click here to view our feedback.
Brussels, July 25, 2020: Press Release SEPA API Access Scheme
The European Third Party Payment Providers Association (ETPPA) would like to welcome the decisions of the European Retail Payments Board (ERPB) earlier this month to confirm ETPPA as a full member representing the Third Party Provider industry and to reinstate the work on a SEPA API Access Scheme later on this year, as described in their statement. ETPPA’s preference would have been to restart it right away, but we can appreciate the ERPB’s desire for some preparatory steps beforehand.
Click here to view the press release.
Brussels, July 24, 2020: ETPPA provides feedback to EPC consultation on payer-presented data
ETPPA today provided feedback to the EPC's consultation about the “Technical Interoperability for MSCTs based on payer-presented data”. We have suggested that the MSCT ecosystem is much more complex than described and that considering all the interactions between the various players will therefore need a more complex model, which we have provided directly to the working group and which we hope will be considered, because that will be essential for creating a truly level playing field between all types of Mobile SCT Service Providers including PISPs.
Click here to view our feedback.
Brussels, July 6, 2020: ETPPA provides feedback to EBA consultation on AML/CTF
ETPPA today provided feedback to the EBA's consultation on the guidelines for AML / CTF risk factors. We have raised some fundamental concerns on the scope of the implied AML requirements for AISPs and PISPs, and in particular for AISPs that do not conduct financial activities. We requested that the AML guidelines are not finalised until the conclusion of the EU Commission’s consultation. If there are any AML requirements for PISPs, it should be clarified that their “customers” are in almost all cases the online-merchants, not the account holders.
Click here to view our feedback.
Brussels, June 26, 2020: ETPPA provides feedback to EC consultation on Retail Payments
ETPPA today also provided feedback to the EC's consultation on a retail payments strategy for the EU. We are advocating an open PSD2-based approach to challenge the dominant cards and wallets from the East and West with superior instant payments technology to regain EU payments sovereignty. The ETPPA's European Retail Payments Framework (ERPF), which is designed to be accessible to all EU citizens in all member states within very short timescales by facilitating interoperability and competition between multiple retail payment solutions, still needs support and some effort from the authorities. So we also used this opportunity to explain and request the missing bricks.
Click here to view our feedback.
Brussels, June 26, 2020: ETPPA provides feedback to EC consultation on Digital Finance
ETPPA has provided feedback to the EC's consultation on a new digital finance strategy for Europe / FinTech action plan. In line with the feedback we provided earlier this year to the UK FCA, we are suggesting a GDPR-based approach for the access and portability of other financial and non-financial data, rather than extending PSD2-type licenses and regulations beyond payments data.
Click here to view our feedback.
Brussels, June 9, 2020: ETPPA provides feedback to EPC SCT Inst consultation
ETPPA has provided feedback to the European Payments Council's SEPA Instant Credit Transfer Rulebook - 2020 Change Request Public Consultation Document. We are supporting the change requests suggested by EuroCommerce to add features to SCT Inst enabling better competition with card schemes, and thereby opposing the EPC recommendation to downstream these features to their new (proprietary) Request-to-Pay (RTP) scheme, because these would then not be available to PSD2-based open RTP schemes.
Click here to view our feedback.
Brussels, June 8, 2020: ETPPA welcomes EBA’s recognition of obstacles
The European Third Party Payment Providers Association (ETPPA) would like to welcome the European Banking Authority’s new “Opinion on obstacles to the provision of third party provider services under the Payment Services Directive” dated June 4, 2020.
This long awaited Opinion positively confirms a number of key areas that the ETPPA has been advocating for on behalf of its members, which are in the clear interest of consumers and merchants across Europe who use these services every day.
Click here to view the full statement.
Brussels, June 5, 2020: ETPPA is excited to welcome Plaid as new full member! #plaid
Plaid is a US-headquartered payments company that operates across seven countries globally. In Europe Plaid is licensed as an AISP and covers Spain, France, Ireland, the Netherlands and the UK. It is great to have Plaid on board to strengthen the voice of payment innovators in Europe and we look forward to supporting Plaid across the European payments regulatory and industry space!
Brussels, March 17, 2020: ETPPA provides feedback to UK FCA Open Finance consultation
ETPPA has provided feedback to the UK Financial Conduct Authority's Call for Input to explore the opportunities and risks arising from open finance. Rather than extending PSD2-type licenses and regulations beyond payments data, we are suggesting a GDPR-based approach for the access and portability of other financial and non-financial data.
Click here to view our feedback.
Brussels, January 30, 2020: Industry veteran Dr. Ruth Wandhöfer joins ETPPA
ETPPA are pleased to announce industry veteran Dr. Ruth Wandhöfer joining as strategic adviser. Ruth brings with her more than 18 years of regulatory and banking experience. Her focus will be on promoting the interests of European TPPs, and contribute to the constructive dialogues with banks, central banks, market infrastructures, regulatory and industry bodies. Ruth commented “I am pleased to support the ETPPA and its members in looking at the intended and unintended consequences of established, recent and yet to be written rules and regulations, helping European TPPs to continue to provide safe, scaleable and user friendly solutions to the benefit of European consumers and merchants.
I will be reaching out to all members in the coming weeks to help prioritise our efforts and look to deliver what our members need from the ecosystem.”
Click here to view the announcement.
Brussels, November 20, 2019: ETPPA letter to EC VP Valdis Dombrovskis and the ECB's ERPB Chair about the creation of a European Retail Payments Framework
Click here to view the letter.
Brussels, September 6, 2019: Joint PSD2 Task Force Update: Banks and TPPs provide a progress update of their joint PSD2 task force to the European Commission, highlighting the urgency for National Competent Authorities to allow flexibility prior to the 14-Sep deadline
Click here to view the letter.
Brussels, June 18, 2019: Press Release: Next Stage of EU Directive “will create widespread customer disruption affecting many millions of consumers and businesses throughout Europe” says Fintech bodies
Click here to see the press release.
Click here to download the The Unintended Consequences of PSD2 RTS document.
Strasbourg, April 16, 2019: Letter from MEP Markus Ferber to European Commission Vice-President Valdis Dombrovskis on the "Implementation of PSD2"
Markus Ferber, member of the European Parliament and their PSD2 trilogue lead, emphasizes the most fundamental requirements for a smooth PSD2 implementation to ensure that there will not be any deterioration of existing TPP services post 14-Sep-2019.
Click here to view the letter.
Brussels, April 9, 2019: Letter to all EU National Competent Authorities in charge of banking supervision on "PSD2 TPP Business Continuity"
ETPPA asks all NCAs to support TPP business continuity post 14-Sep-2019 by ensuring that banks and other ASPSPs cannot block any of their user interfaces for contingency measures and allowing TPPs to fulfil their eIDAS identification obligations unilaterally via HTTP header signatures.
Click here to view the letter.
Brussels, April 4, 2019: European Third-Party Provider Association established
The non-profit organisation has been established by the founding members Bankin’, Eurobits, PPRO, Sofort, Trustly
Click here to view the news item.