The second payment services directive (Directive (EU) 2015/2366, “PSD2”) as well as well as the fourth anti-money laundering directive (Directive (EU) 2015/849, “4AMLD”) gives EU member states’ (“Host Member State”) authorities the competence to require those payment service providers or e-money issuers having its head office in another EU member state and acting in the territory of that Host Member State in forms other than a branch to appoint a central contact point in the territory of that Host Member State. The appointment of such central contact point and the obligations connected with such appointment might have a significant impact on the provision of payment services or e-money business under the provisions of the European Passport.
PSD2 RTS for strong customer authentication and common and secure open standards of communication published
What are the practical implications? What does it mean that the RTS are now in force? And isn’t PSD2 already in force since 13 January 2018?
On 2 April 2015, the FCA published a statement on its website as follows:
Security of Internet Payments – EBA Guidelines
The European Banking Authority (EBA) has published its final Guidelines on the Security of Internet Payments. We are fully supportive of the objectives behind the Guidelines and agree with the importance of consumers being protected against fraud when making payments online. Ensuring the security of payments and the protection of sensitive customer data is a critical part of the infrastructure of robust payment systems.
The European Banking Authority (‘EBA’) published a consultation paper in October on the implementation of its Guidelines on the security of internet payments, developed in conjunction with the European Central Bank (‘ECB’), with the basis of much of the Guidelines stemming from recommendations put forward by the European Forum for the Security of Retail Payments. Dr. Matthias Terlau and Dr. Daniel Walter of Osborne Clarke discuss what is expected of payment service providers in the context of the proposed Guidelines.
The European Banking Authority (‘EBA’) published a consultation paper on the implementation of its Guidelines on the security of internet payments, the output of work undertaken in conjunction with the European Central Bank (‘ECB’), with the basis of much of the guidelines being work by the European Forum for the Security of Retail Payments. The EBA expects these proposed guidelines to enter into force in August 2015. Dr. Matthias Terlau and Dr. Daniel Walter of Osborne Clarke discuss the compliance expectations for payment service providers and analyse the critical aspects of the proposed guidelines.