Ecommerce Europe’s position on the upcoming PSD2 revision


This Spring (28 June 2023), the European Commission is expected to publish a report on the implementation of the Payment Services Directive 2. Based on the conclusion of this report, the European Commission may also propose amendments to the existing Directive – or potentially a whole new legislative act.

Ecommerce Europe welcomed the original Directive, but does believe that a series of amendments, as well as a new and stronger approach to enforcement of existing rules and standards, are necessary.

In its position paper, Ecommerce Europe highlights some key recommendations to improve the current framework and fulfil its original objectives.

Firstly, there are remaining barriers and regulatory gaps that need to be addressed to truly foster the development of open banking. We believe that the European Commission should build on the PSD2 framework in that regard, and continue the work of harmonising and enforcing the rules.

Secondly, we believe that the implementation of Strong Customer Authentication should focus on its objective of securing transactions without scarifying authentication success rates and consumer experience. The standards, and their implementation, have overly focused on the means rather than these objectives (e.g. prescriptive interpretation of authentication factors). We therefore would like to call for a stronger focus on better and harmonised implementation of existing standards (e.g. exemptions), on authentication success rates, as well as on re-evaluating the role of merchants in fraud prevention.

Finally, we believe that the revision of PSD2 should touch upon connected issues such as competition, transparency and costs of payments in the EU. Indeed, this legislation could be leveraged to address other issues currently present in the EU retail payment market to truly benefit end-users.

You can read here our full position on the revision of the PSD2.