European Third Party Providers Association

Brussels, June 16, 2025: Joint EU FinTech letter on FIDA - views on European Commission simplification non-paper

ETPPA has co-signed a joint EU FinTech industry letter to the European Commission, Council of the European Union, and European Parliament, laying out our joint views on the European Commission simplification non-paper (dated 16-May) on the proposed EU regulation on Financial Data Access (FIDA).

As representatives of the European fintech ecosystem, we would like to convey our continued support for the European Commission’s proposed Regulation on Financial Data Access.

We welcome many positive provisions, which we believe will help streamline the FIDA regulation, for example: alignment with PSR/PSD3; for the regulation to not be too prescriptive; and lessons from PSD2.

At the same time, we would urge reconsideration of the following provisions, which would be extremely detrimental to EU fintechs, to their contribution to Europe’s competitiveness, and to customers’ ability to leverage their data in more innovative ways: i) limiting FIDA to retail customers data only; ii) excluding credit rating agencies from scope; iii) limiting historical data; iv) not allowing for a market led approach when it comes to FIDA schemes.

The letter was co-signed by ETPPA, together with the Spanish Association for Fintech and Insurtech (AEFI), the French Association of Payment and Electronic Money Institutions (AFEPAME), Digital Invest Germany, the European Digital Finance Association (EDFA), France FinTech, PSD2 Software Industry Group (PSD2SIG), and the Swedish FinTech Association.

Click here to read the full joint letter.

Brussels, March 31, 2025: Joint EU FinTech letter on a way forward for FIDA

ETPPA has co-signed a joint EU FinTech industry letter to the European Commission, Council of the European Union, and European Parliament, on a way forward for the proposed EU regulation on Financial Data Access (FIDA).

Whilst we are aware that there has been considerable push back by incumbents, against the FIDA Regulation, this comes as no surprise and is a repeat of similar arguments raised by incumbents when PSD2 was proposed to level the playing field and increase competition in the payment services landscape. Under no circumstances, would we see a withdrawal of FIDA being necessary or beneficial for the competitiveness of the EU. EU FinTechs/TPPs/FISPs hold the potential for increasing financial literacy in Europe and increasing Europe’s competitiveness. It is time that people take control of their data and be better informed and equipped for their financial future.

The letter suggests three areas where targeted adjustments could be made to FIDA, during trilogue negotiations.

1. Taking a more customer centric approach: FIDA’s primary focus should be enabling customers to take control over their data so that they can access and re-use it as they see fit, thereby allowing access to a wider range of competitive and innovative services across Europe and beyond the products and services offered by incumbent data holders.

2. Giving customers continuous access to their data with a user interface: Many, if not most, financial service providers are already providing 24x7 access to all their customers and the time has come to enforce this on the rest. Customers should be able to access and retrieve their data remotely on an ongoing basis, which means that all financial data holders should be obliged to provide at least one (online or mobile and preferably API-based) customer interface, which is accessible at any time.

3. Differentiate clearly between “data re-use” and “data sharing”: The key term here is ‘access’, not ‘sharing’, in order to enable customers to re-use their data and allow FinTechs to provide value-added services without any loss of confidentiality. FIDA should first and foremost enable customers to take control over their data so that they can access and re-use it as they see fit - with or without third party assistance.

The letter was co-signed by ETPPA, together with the Spanish Association for Fintech and Insurtech (AEFI), the French Association of Payment and Electronic Money Institutions (AFEPAME), the European Digital Finance Association (EDFA), the Electronic Money Association (EMA), France FinTech, Free Insurance Data Initiative (FRIDA), PSD2 Software Industry Group (PSD2SIG), and the Swedish FinTech Association.

Click here to read the full joint letter.

Brussels, March 20, 2025: ETPPA executive members meet with European Commissioner for Financial Services to discuss open banking, the move to open finance and the future for TPPs in Europe

On 20-March-2025 ETPPA's executive members met with European Commissioner Maria Luís Albuquerque, responsible for Financial Services and the Savings and Investments Union.

The meeting saw an exchange on PSR/PSD3, FIDA, and the future for TPPs and fintechs in Europe.

On PSR/PSD3, ETPPA provided views on progress being made by the Council, and the position already reached by the European Parliament.

Regarding the proposed FIDA Regulation, ETPPA highlighted its support, once again, and emphasized that many of its members have been delivering open finance services for many years, some for over two decades. Consequently, ETPPA stressed the critical importance of ensuring that the FIDA regulation enhances, rather than diminishes, the quality and scope of these services.

The meeting was also an opportunity to discuss the important role Third Party Providers play in making payment services more competitive and innovative in Europe, for the benefit of consumers.

Brussels, March 16, 2025: ETPPA feedback to European Commission consultation on an EU Startups and Scaleups strategy

In 2025, the European Commission will adopt an EU Startup and Scaleup Strategy.

The Commission has put startups among the key priorities of its mandate, with the goals of closing the innovation divide between the EU and its global competitors and boosting European competitiveness. It has now become urgent to address the financial, regulatory and administrative obstacles that limit or slow down startups from scaling up into mature, profitable companies in the Single Market and to incentivise them not to relocate out of the EU.

The European Commission issued a call for evidence on 16-Feb-2025 in order to gain stakeholder feedback on existing obstacles for startups and scaelups. ETPPA agrees wholeheartedly that regulatory and bureaucratic burdens, as well as fragmentation, are something third party providers (TPPs) and other fintechs experience on an ongoing basis.

ETPPA provided input to the European Commission on lessons learned from PSD2 obstacles, experienced by TPPs. Additionally, we point out some lessons for startups and scaleups, taken from the EU's AML Regulation, the AI Act and the Instant Payments Regulation regarding direct access to safeguarding accounts by non-bank PSPs.

Click here to read ETPPA's feedback to the European Commission.

Brussels, Dec. 5, 2024: ETPPA opposes Council General Approach text on FIDA as it risks undermining Open Finance in Europe

Following news of the Council reaching a General Approach agreement on the Financial Data Access (FIDA) regulation, ETPPA has issued a statement opposing the Council's text and favouring the European Commission's proposed wording.

ETPPA believes that the Council's General Approach agreement to FIDA could hinder open finance in Europe. In particular, ETPPA opposes the following Council provisions:

Art. 6(4)(h) provides that data users shall “not transfer customer data to any third party”. This would not only contravene GDPR and PSD2 (to be replaced by PSR), but it would also jeopardise the very aim of FIDA, to move towards a framework for financial data access and innovation in the EU.
Art. 11 provides for too short a time period for industry to have FIDA schemes up and running and calls for swifter regulation of FIDA schemes via a delegated act. ETPPA strongly believes that interaction between data holders and data users must be left to the market.
Recital 9 severely limits data under the scope of FIDA. ETPPA advocates for a much more customer centric approach, so that data included demonstrates high value added for the "customer", i.e. the data owner, not merely for "financial innovation".

If the final legal text reflects the Council position, in this form, implementing FIDA might not benefit customers or the financial services industry. This would be a missed opportunity to advance from Open Banking to open finance more broadly.

FIDA should focus solely on enabling customers’ access to their data and leave the interaction between all other parties entirely to the market, following the SPAA role model. From the three options currently on the table, ETPPA would strongly favour the text proposed by the European Commission as it fosters a move towards financial data access in Europe, rather than hampering it.

Click here to read ETPPA's statement.

Brussels, Nov. 1, 2024: ETPPA feedback to ERPB ‘Fit in the Ecosystem’ digital euro questions

ETPPA has provided its feedback to the Euro Retail Payments Board (ERPB) on three important questions, put to ERPB members in October 2024. The questions asks for industry views on how a digital euro could impact EU players strategic relevance; how a digital euro could be as cost effective as possible; and how a digital euro could impact EU players business models.

ETPPA believes that a Digital Euro should focus on the established home ground of central bank money as tokens in a wallet, exchanged offline peer-to-peer, i.e. essentially providing a more flexible and less costly “better version of cash”.

We see numerous problems with suggestions to date to extend the scope of central bank money into new territories, e.g. e-commerce, and add an account-based variant and thereby duplicate the infrastructure of private electronic payments. These ambitions of the Digital Euro pose very clear risks for crowding out existing market players and acting as an extreme detriment to EU players strategic relevance. A Digital Euro would not play a role outside the EU, yet it would compete with many pre-existing private sector payment solutions which have seen years, if not decades of private sector investment

Click here to read ETPPA's feedback.

Brussels, Oct. 8, 2024: ETPPA participates in European Payments Council webinar on the Impact and Opportunities of the SPAA Scheme

On 8-Oct-2024 ETPPA's Vice Chair Arturo González Mac Dowell, who also co-Chairs the EPC's Multi-Stakeholder Group on SEPA Payment Account Access (SPAA), took part in an exclusive webinar organised by the European Payments Council (EPC) titled “Fostering Open Banking in Europe: The Impact and Opportunities of the SPAA Scheme”. The webinar looked at how SPAA can benefit banks, third parties and consumers as it builds on Open Banking in the EU.

Click here to access a recording of the webinar.

Brussels, Sep. 26, 2024: ETPPA co-signs letter to ECB on access by non-bank payment services providers to central bank accounts

ETPPA has co-signed a joint industry letter to the European Central Bank, in response to its July 2024 policy on access by non-bank payment service providers to its central bank payment systems.

We urge the Eurosystem to consider a calibrated approach allowing some safeguarding to take place, applying suitable restrictions, in a similar manner to that utilised for the digital euro. This could provide benefits for the payment system and its users.

Excluding safeguarded status for settlement funds has the potential to make direct participation in SEPA, a future digital Euro, and other designated payment systems, economically unworkable.

We remain committed to working collaboratively and acknowledge the Eurosystem/ECB’s role in meeting its monetary policy and financial stability objectives. We hope this can be achieved whilst balancing the interests of all payment services providers and maintaining effective competition in the financial services marketplace.

Click here to read the joint letter.

Brussels, Sep. 16, 2024: Euro Retail Payments Board publishes report of Working Group on fraud related to retail payments

The European Central Bank's Euro Retail Payments Board (ERPB) has published a report on fraud related to retail payments. The report is the work of the ERPB's fraud working group, which ETPPA participates in to represent the voice of TPPs in Europe.

To prevent and mitigate fraud more effectively and across the fraud chain, the working group has identified four ‘gamechangers’, as follows:

Gamechanger 1: Cross sectoral collaboration & responsibilities;
Gamechanger 2: Sharing Fraud insights & data;
Gamechanger 3: Supervisory enforcement cooperation at EU level across sectors;
Gamechanger 4: Secure product design for consumer protection.

For each gamechanger, the working group recommends several actions to be implemented by EU and national authorities, as well as institutions and entities from the private sector.

Click here to read the full report.

Brussels, June 21, 2024: ETPPA supports Joint Industry Call To Reconsider Approach On Virtual IBANs

The EU digital payment industry urges Member States to reconsider the Belgian Presidency proposal to assimilate virtual IBANs to traditional IBANs, and to mandate payment service providers to open a payment account with a credit institution in each Member State they operate in. The result will be to materially reduce the ability of payment service providers operating cross-border to help consumers and merchants manage their payments and overcome IBAN discrimination. More evidence is needed on the risks implied by virtual IBANs, and the potential risk mitigation measures should be assessed against their impact on competition, innovation and consumer choice in the EEA.

Click here to read the joint industry statement.

Brussels, Feb. 20, 2024: ETPPA Calls for Wider Consideration of Open Banking Provisions in EU’s Payment Services Regulation

Following last week’s vote by the European Parliament’s ECON committee on the proposed EU Payment Services Regulation (PSR) and PSD3, ETPPA would like to express its concern that several crucial Open Banking considerations pertaining to Account Information Services (AIS) and Payment Initiation Services (PIS) did not make it into the ECON committee’s final text.

We fear these missing provisions would make it impossible for European fintechs to properly compete with the likes of ApplePay and GooglePay and could jeopardise the competitive nature of AIS and PIS.

ETPPA would encourage the co-legislators to include these essential missing provisions, in order to not backtrack from PSD2 and the lessons learned.

Click here to read ETPPA's statement and our suggestions on missing provisions.

Brussels, Jan. 31, 2024: Joint statement of ETPPA, EMA, EPIF, EFA, and OFA on: AMLR technical trilogues - RECITAL 34 discriminating against European fintechs

Following the joint EU fintech industry statement on the EU's proposed AML Regulation, issued on May 17, 2023 (see here), ETPPA, together with EMA, EPIF, EFA and OFA, are calling on the co-legislators and the European Commission to clarify the compromise text reached on recital 34 of the AML Regulation in the technical trilogues, in order to ensure that the text does not kill European payment initiation services (PIS).

In summary:

● Inequitable treatment of PISPs compared to card acquirers

● Homegrown EU fintechs to be left at serious and unwarranted competitive disadvantage

●EU legislators urged to clarify Recital 34 so that PISPs’ CDD obligation relate only to merchants

It is our view that the current draft compromise text for recital 34 needs to be further clarified in two crucial respects, and as we explain in the joint statement. We are confident this can be done within the realm of the already existing political agreement. Otherwise, it will be impossible for European PISPs to compete with other payment solutions such as card acquirers (Visa/Mastercard), ApplePay and Ideal/EPI, all of whom have to perform due diligence only on the merchant to whom they provide services.

Click here to read the joint statement.

Brussels, Jan. 25, 2024: Monitoring the Implementation of PSD2 - empirical research conducted by 5 TPPs in France

Five TPPs - Linxo, Lyra Collect, Perspecteev (Bridge), Fintecture, and Powens - have published a detailed study on AIS and PIS journeys, collaborating with an external consultancy firm to ensure the confidentiality of shared and exchanged data. The study identifies critical pathways that need to be corrected as soon as possible by confirming that the issue is common to all TPPs, initiating discussions, and alerting the relevant authorities if necessary.

Currently, regulatory efforts are in full swing to both thoroughly revise PSD2 and extend its concepts to the finance sector. In this context, it is increasingly important to manage and measure the impact of PSD2 on customer usage, and more broadly in terms of innovation, compliance with competition rules, and consumer protection. Building on these observations, the study lists a number of key findings and provides practical and implementable recommendations for the anticipated upcoming regulatory developments, as follows:

Enhance the monitoring of functional processes implemented by ASPSPs to identify any potential issues and ensure the success of operations facilitated by TPPs.
Strengthen the monitoring of operations intermediated by TPPs to ensure the proper use of statuses recommended by STET.
Prohibit the cancellation of successfully initiated transfers.
Enhance information exchange between market participants to facilitate a more efficient fight against fraud.
Implement error messages for failed authentications on the fallback interfaces of banking institutions.
Improve ASPSP communications regarding APIs and their operational status.
Harmonize practices across institutions for automated requests initiated by AISPs towards ASPSPs.
Implement error messages on the main interface of banking institutions in the event of SCA failure.
Optimize SCA processes.

Click here to read the full report.

Brussels, Jan. 25, 2024: Joint industry letter on PSR foreign exchange rate transparency in cross-border payments

ETPPA, together with a number of EU fintech trade bodies, has issued a joint statement on PSR foreign exchange rate transparency in cross-border payments and the use of an aggregated live mid-market benchmark rate.

The requirement to disclose FX mark-ups against a uniform benchmark rate is an important step that will promote transparency, empower consumers, and foster competition in the cross-border payments and remittances market and we applaud the Commission for taking this step. However, the current PSR proposals introducing a central bank benchmark rate and reference to fees in percentage terms will have a negative impact on both consumer understanding as well as the PSP's ability to charge effectively and in line with the real time nature of the FX market.

To achieve meaningful transparency provisions that would enable comparison and competition in the cross-border payments market, we urge co-legislators to:

· Introduce an aggregated live mid-market exchange rate provided by neutral entities as the benchmark rate.

· Introduce the disclosure of mark-ups in monetary terms or as a 'total fee' instead of percentages.

Click here for more and to view the joint letter.

Brussels, Nov. 8, 2023: From Open Banking to Open Finance - Fintech Day 2023 - Sweden

ETPPA outlined the route from Open Banking to Open Finance based on the lessons learned from PSD2 and finding the right balance between regulation, collaboration and standardisation - reminding the key recommendations of our Open Finance Manifesto that open finance regulation should be customer centric, technology neutral, horizontal and proportionate.

Click here to view our presentation.

Brussels, Nov. 6, 2023: ETPPA publishes position on proposed payment services regulation (PSR)

ETPPA strongly supports the Commission’s proposal to review PSD2 and is pleased to see the Commission’s vision to reaffirm open banking in Europe. Moving many parts of the directive into a regulation is a positive development, which will hopefully remove much of the fragmentation we have seen across the EU. We particularly welcome the PSR’s focus on improving APIs by increasing the enforcement of existing law, mandating more functionalities, maintaining PSD2’s non-contractual obligation and non-charge provision for TPP access to payment account data and prohibiting obstacles.

That said, some of our most critical recommendations are not part of the proposed text, and we hope the co-legislators will be willing to recommend their inclusion in order to ensure PSR strikes the right balance to foster competition and innovation in the EU. In our position paper we list these points and the rationale for why they are required in the interest of consumers, merchants, competition and innovation in the European Retail Payments arena.

Click here to view the position paper.

Brussels, Nov. 6, 2023: ETPPA publishes position on proposed financial data access regulation (FIDA)

For several years, ETPPA has contributed to the European Commission’s work in the Financial Data Access arena by participating in its Financial Data Space Expert Group, its Open Finance report and providing feedback to its targeted consultation. We are pleased that some of our recommendations were adopted in the FIDA proposal published on June 28, which has great potential for a move from open banking to open finance more broadly in Europe.

Unfortunately, some of our most critical recommendations are not part of the proposed text, and we hope the co-legislators will be willing to recommend their inclusion. For that, our position paper lists these points and the rationale for why they are required to enable financial services customers to take control over their data and thereby getting access to a wider range of competitive and innovative services across Europe.

Click here to view the position paper.

Brussels, July 3, 2023: ETPPA welcomes the European Commission’s proposal for a Digital Euro

ETPPA welcomes the Digital Euro proposal published on June 28, which comes at an exciting time for the EU’s regulatory landscape of payments.

Importantly, the proposal clarifies that any account-based digital euro would fall under PSD2 and therefore be accessible to TPPs as any other ‘online payment account’, and it mandates an offline version right from the start, where bank and non-bank PSPs should be able to compete on a more level playing field, and which is likely to be more popular.

Click here to view the statement

Brussels, June 30, 2023: ETPPA welcomes European Commission’s proposal on Financial Data Access (FIDA) but flags the importance of a customer centric approach

ETPPA welcomes the FIDA proposal published on June 28, which has the potential for a move from open banking to open finance more broadly in Europe, but we would like to highlight the importance of taking a more customer centric approach to this framework.

It should focus on allowing consumers and businesses to access and re-use their data as they see fit in order to obtain a broader range of products and services than the data holder is offering itself. The interaction between industry players within the framework should be left to self-regulation for as much as possible.

Click here to view the statement, and here for our Open Finance Manifesto

Brussels, June 29, 2023: ETPPA welcomes the European Commission’s PSD3/PSR proposal

ETPPA welcomes the European Commission’s proposed package on a review of PSD2, published yesterday. Moving to a regulation is a positive development and will hopefully remove any fragmentation across the EU.

It contains several good provisions for TPPs, for example the list of prohibited obstacles, which we hope the co-legislators will make clear, is non-exhaustive. ETPPA will continue to strive for, amongst other things, more stringent governance, excellent APIs, and immediate contingency whenever that is not the case. We also believe that payment initiators must be allowed to assess any non-execution risks before initiating and that strong customer authentication is only needed when money is actually moved, not just being looked at.

Click here to view the statement.

Brussels, May 17, 2023: Joint statement of ETPPA, EFA, EMA and EPIF on AMLR trilogues - call for level playing field in Europe amongst all fintech providers

With trilogue negotiations kicking off this month on the proposed EU anti-money laundering regulation (AMLR), ETPPA together with the European Fintech Association (EFA), the Electronic Money Association (EMA) and the European Payment Institutions Federation (EPIF) call on the co-legislators to ensure a level playing field amongst all fintech providers when it comes to their obligations to perform customer due diligence (CDD) on their customers.

If PISPs are kept in scope of AMLR, it will then be of utmost importance to make clear that PISPs serving merchants under no circumstances have to perform CDD on payers. The established practice in Europe, as well as the rest of the world, is that the account-servicing payment service provider (typically a bank) performs CDD on its customers, the account holders, while merchant-facing payment services providers perform CDD on their customers which are the merchants. Indeed, no one who has paid with debit cards or with online banking solutions such as iDEAL (recently acquired by the European Payment Initiative - EPI), or indeed Apple Pay or Google Pay, has ever been asked to verify its identity and address, or provide source or proof of source of funds (such as a pay slip) to the merchant-facing acquirer in order to effect a payment.

ETPPA, EFA, EMA and EPIF call on the European co-legislators to ensure in AMLR trilogues that Recital 34 of the AML Regulation makes it 100% clear that merchant-facing PISPs should perform CDD on the payee only, both in terms of the establishment of a customer relationship and for occasional transactions, and no matter whether they touch payee (merchant) funds or not. This is required to put PIS on a level playing field with cards, online banking payment solutions such as iDEAL (EPI) and other relevant payment solutions.

Click here to view the joint statement.

Brussels, May 11, 2023: Joint statement from European Fintech Associations calling on co-legislators to ensure payments are kept in scope of the Digital Identity Regulation

The European Fintech Associations ETPPA, EPIF, EFA, EDFA, and AEFI, have issued a joint statement highlighting the importance of keeping payments under scope of the EU eID Regulation.

Digital identity should be able to substitute physical identity documents in any situation where such verification and authentication of a citizen or business is required. It would not be reasonable to inhibit digital innovation by excluding entire industries from the scope of the regulation, as suggested recently by some bank associations. Keeping payments in scope and developing such interoperability standards, will allow consumers to make instant payments using their smartphone in a frictionless standardised and non-proprietary manner across all EU countries. This will not only benefit consumers, businesses and fintechs, but it will also add to the EU’s continued wealth creation.

The European Fintech Associations therefore call on the co-legislators to ensure that payments are kept fully in scope.

Click here to view the joint statement by ETPPA, together with the European Payment Institutions Federation (EPIF), the European Fintech Association (EFA), the European Digital Finance Association (EDFA) and the Spanish Fintech and Insurtech Association (AEFI).

Brussels, March 24, 2023: ETPPA publishes response to sixth ERPB technical session on a digital euro

ETPPA's biggest concerns in relation to the latest design choices being proposed are the foreseeable disruption of the retail payments ecosystem, the missing incentives for intermediaries to drive the use of a D€ and the high number of use cases being considered for launch. The role of acquirers in general, and that of PISPs in particular, appears jeopardised, which would make the suggested compensation model infeasible.

Click here to view ETPPA's response.

Brussels, March 15, 2023: ETPPA launches Open Finance manifesto in presence of DG FISMA

ETPPA launched its Open Finance Manifesto in Brussels, in the presence of the European Commission's Directorate General for Financial Stability, Financial Services and Capital Markets Union.

The manifesto, which is the result of extensive consultation with industry experts, distinguished members of academia and ETPPA's members, calls for five core principles to be included in any EU Open Finance Framework:

a light touch horizontal regulation since all industries are increasingly opening up;
a customer centric model;
a technology neutral approach;
APIs first, but not APIs only;
a level playing field between open finance and open data more broadly.

You can find the manifesto here. In case you are interested to learn more about this manifesto or wish to support it, please contact us at: info@etppa.org

Brussels, February 22, 2023: ETPPA position paper on European Commission's proposed instant payments regulation

ETPPA has long been a proponent of a legislative proposal mandating instant payments across the EU, as instant payments has been the missing brick in the PSD2 ecosystem and there has been a clear need for swift legislation here in order to help Payment Initiation Service Providers (PISPs) and fintechs in general leverage the huge investments already made into PSD2 infrastructure. Whilst ETPPA commends the Commission's proposal, we have identified six core issues, which should be addressed by the co-legislators to future proof the use of instant payments in the EU’s retail payments market.

Please find here ETPPA's position paper listing the six core issues.

Brussels, January 23, 2023: ETPPA publishes response to fifth ERPB technical session on a digital euro

ETPPA is making additional recommendations for a successful D€. The proposed one account per citizen with a limited balance would launch the project on the wrong foot, hinder the take-up and undermine the monetary anchor objective. Mandating zero overnight balances to merchants would be equally counterproductive and cause unnecessary overhead. Leaving value-added services fully to the market will be another essential ingredient.

Click here to view ETPPA's response.

Brussels, December 3, 2022: ETPPA publishes response to fourth ERPB technical session on a digital euro

Programmable payments should be left to the private sector and programming the D€ itself should be investigated. Access to D€ accounts should be in line with PSD2, but a token-based approach would allow for much more innovation and competition amongst intermediaries. Current limitations for PISPs in relation to QR-codes and mobile proxies should be lifted and POS and P2P use cases should include the use of BLE and UWB, which allow for more security and dynamic linking in proximity payments.

Click here to view ETPPA's feedback.

Brussels, November 3, 2022: ETPPA launches public registry of PSD2 API obstacles

ETPPA has published a new EU-wide registry of obstacles (available here) compiled by Third Party Providers (TPPs), which highlights the many problems experienced with PSD2 APIs.

Following more than three years since the introduction of PSD2 APIs we still don’t see a successful and coherent implementation of PSD2 that Fintechs can succeed on and that payment service users can rely on. This public registry shall contribute to the fruition and full implementation of PSD2 by disclosing these obstacles, and thus putting additional pressure for their much needed removal.

ETPPA would like to encourage:

banks to consult the registry, acknowledge and address their obstacles;
national competent authorities to consult the registry and request evidence of non-compliance that can form the basis for investigating a bank's dedicated interface;
the EBA to consult the registry to see where NCAs fail to achieve compliance.

Click here to view the press release.

Brussels, October 26, 2022: ETPPA welcomes European Commission proposal on Instant Payments

ETPPA commends the Commission for mandating instant payments and - most importantly - to remove any premium fees over standard transfers, which means that they will be free in most cases. This is crucial to ensure that the true benefits of instant payments can be made available to all EU consumers. Instant Payments must be free to the payer and final to the payee to be used for retail payment solutions as proposed in our ERPF.

ETPPA would call on the co-legislators to support this mandate and to ensure the certainty of instant payments, thereby future proofing the EU’s retail payments market so that it can compete globally.

Click here to view the press release.

Brussels, October 25, 2022: European Commission Expert Group on Financial Data Space publishes Open Finance Report

Today the European Commission's Expert Group on European Financial Data Space published its Open Finance Report, detailing their views for an Open Finance ecosystem in Europe. This report is the result of diverse opinions and input from an array of industry stakeholders. It contains valuable input which can be taken forward by the European Commission.

The expert group will continue to work on certain policy areas identified in this report, with a view to further developing and discussing more detailed technical issues related to the implementation of this report and open finance in general.

ETPPA's Chair Ralf Ohlhausen has contributed extensively to this important report as a member of the expert group.

Click here to view the expert groups Open Finance Report.

Brussels, September 29, 2022: ETPPA publishes an overview of their European Retail Payments Framework (ERPF)

The European Retail Payments Framework (ERPF) is ETPPA's proposal in reply to the request of the European Central Bank and the European Commission for pan-European market initiatives for retail payments at the point-of-interaction (POI).

Our proposal was designed to address the given objectives and thereby provide unprecedented EU-wide customer reach from day one, the best in class user experience across all countries, significant cost benefits, unmatched safety and security, full European sovereignty and all the required ingredients for global acceptance.

Click here to view the ERPF Overview, or here to download a PDF version, or here for the Press Release.

Brussels, September 22, 2022: ETPPA publishes response to third ERPB technical session on a digital euro

The role of digital euro intermediaries should be open to non-bank PSPs and not just to credit institutions, which are currently eligible for ECB accounts. An account-based approach will create confusion with other payment accounts and jeopardise the electronic retail payments ecosystem. Using a token-based approach instead, would allow more innovation and competition, which otherwise will come again from non-EU territory.

Click here to view ETPPA's feedback.

Brussels, August 29, 2022: ETPPA welcomes Dr. Michael Salmony as Strategic Adviser

ETPPA are pleased to announce the appointment of Dr. Michael Salmony as strategic adviser to ETPPA. Michael is an internationally recognised leader on strategy of business innovation in digital and financial services with a particular focus on Open Banking, Open Finance, Open Data, and the Fintech world in general. He joins Dr. Ruth Wandhöfer, who has been advising us for over 2 years already.

Click here to view the announcement, and here to view Michael's bio. At the time, Ruth's appointment was posted here.

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, July 26, 2019: Press Release: Banks and third party providers agree on joint efforts regarding the transition to new payment rules

Click here to see the press release.

Click here to see the Joint Statement

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.

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