Modernising payment services and enhancing open banking: a comparison of recent EU proposals of payment services directive 3 (PSD3) and payment services regulation (PSR) with current PSD2
Modernising payment services and enhancing open banking: a comparison of recent EU proposals of payment services directive 3 (PSD3) and payment services regulation (PSR) with current PSD2

Author(s): Jan Skrabka
Subject(s): National Economy, Law on Economics, Financial Markets, Socio-Economic Research, Sociology of Law
Published by: ADJURIS – International Academic Publisher
Keywords: consumer protection; open banking; open finance; payment services; PSD3; PSR;
Summary/Abstract: The article provides a comparative analysis of the fundamental developments of the recently published EU Financial Data Access and Payments Package. It focuses on the comparison of the proposal of the Payment Services Directive 3 (PSD 3) and a new Payment Services Regulation (PSR) with the current PSD2. Among the main features, the European Commission promises improvements mainly in the protection of Payment Services Users and also in the area of competitiveness in the financial sector. Besides PSD3, the new PSR, which will be directly applicable in the whole EU, will tackle forum shopping by increasing the harmonisation in different Member States. Regarding competitiveness, the proposed framework aims to increase competitiveness by further enhancing open banking with a dedicated interface (API) for exchanging information between market players and providing users with dashboards to monitor and manage their consent with data sharing easily. However, the proposed framework repeals some PSD2 exceptions and imposes unnecessary administrative burden on specific types of businesses, such as foreign exchange services or limited networks, or fails to include sufficient temporary provisions allowing for uninterrupted operations. The article presents a critical discussion of proposed changes and their potential impact on practice. The new framework is just at the beginning of the legislative process, and the finally approved PSD3 and PSR are expected to be applicable in 2026 at the earliest.

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