Position on PSD3 & PSR1

EDFA Publishes Position Paper on PSD3 & PSR1: A Call for Fairer, Smarter, and More Competitive Payments in Europe

The European Digital Finance Association (EDFA) has released its position paper on the European Commission’s proposals for PSD3 and PSR1, offering recommendations to ensure a fairer, more innovative, and secure payments ecosystem in the EU.

While PSD2 aimed to enhance competition and drive innovation, market realities have fallen short. Dominant banks and card schemes have strengthened their positions, while technical and regulatory barriers continue to hinder non-bank providers. PSD3 and PSR1 now present a crucial opportunity to reset the landscape.

EDFA’s key recommendations include:

• Data Standardisation & Quality: Mandate core data fields and consistent structures across channels to enable accurate, automated financial services and support financial inclusion.

• User Experience & App Navigation: Require seamless mobile app-to-app redirection and harmonised SCA processes to reduce friction and abandonment.

• Fraud Liability: Clarify responsibilities between PSPs and banks, particularly in relation to IBAN mismatches and instant payment constraints.

• API Access & Support: Enforce reliable service level standards, real-world testing environments, and clear rules for premium services such as variable recurring payments (VRPs).

• Non-Discrimination of Payment Methods: Ensure A2A payments are treated equally to card payments in functionality, exemptions, and confirmation processes.

• Licensing & Safeguarding: Harmonise licensing standards across Member States and address circular safeguarding requirements that delay market entry.

EDFA supports the Commission’s efforts and urges policymakers to take bold steps to foster real competition, protect consumers, and ensure the resilience and accessibility of Europe’s payment infrastructure.