Dutch Payments Association recognises issues in SEO evaluation report on PSD2
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On 20 June, Finance Minister Sigrid Kaag presented SEO Economic Research’s evaluation of the Dutch implementation of PSD2 (the Revised Payment Services Directive) to the House of Representatives. The Dutch Payments Association recognises the issues identified in SEO’s evaluation report .
These are the report’s main conclusions and recommendations:
- Greater clarity and transparency are needed about the relationship between PSD2 and the GDPR (General Data Protection Regulation). This relationship is currently unclear, creating a strong need for practical guidance;
- The interfaces to banks (digital gateways or APIs) are not standardised. This has resulted in additional costs for both banks and other payment service providers;
- Under PSD2, banks are required to give other payment service providers digital access to payment data and payment services, and may not pass on the associated costs. This can, among other things, reduce innovation and disrupt the balance between costs and revenues, with revenues flowing disproportionately to other parties;
- The national application of relevant European laws and regulations, and the associated supervisory frameworks, are insufficiently harmonised. This has created uncertainty and unintended differences between Member States;
- The ban on surcharging (charging additional fees for certain payment methods) provides insufficient incentive to use the most efficient payment methods.
The European Commission is also evaluating PSD2 through a Targeted Consultation on the Review of PSD2 . The deadline for responses is 5 July 2022. Since mid-April 2022, the Dutch Payments Association has been working in a dedicated PSD2 Review Task Force (TFPR) to prepare a jointly agreed response from its members and stakeholders. The task force is now finalising its response.
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