Regulatory Plan

Regulatory requirements continuously changing

Directives, laws and regulations play a decisive role in payments. They standardise the legal framework conditions, promote fair competition, provide transparency for all participants and support the implementation of political and economic goals, such as fostering innovation or standardising markets.

The many stipulations are always being added to. Due to technical and business developments, these stipulations are continuously being adjusted, extended or revised.

At present, the following rules are relevant for payments:

  • The EU Payment Services Directive (PSD) for the internal market, implemented in Germany via the Payment Services Regulation Act (ZAG, Zahlungsdiensteaufsichtsgesetz) and in the German Civil Code (BGB, Bundesgesetzbuch), regulates the legal framework of a standardised European payment region. In 2018 this directive will be replaced by the revised Payment Services Directive (PSD II).
    PSD II initially regulates what are known as third-party payment service providers, extends the existing area of application, introduces comprehensive new security requirements and regulates the supervision by the European Banking Authority (EBA). This directive was published on 23/12/2015 in the Official Journal of the European Union and must be implemented as national law by 12/01/2018.
  • The directive for interbank fees (MIF Directive) for card-based payments: interbank fees for debit card payments are limited to 0.2 % and for credit card payments to 0.3 %. There are exceptions for withdrawals from cash machines, commercial cards and 3-party systems.
  • The first and second EU directives on the finality of payments regulate the bindingness of payments in all EU member states. In Germany the directives are implemented via the law for the implementation of the changed banking directive and the changed capital adequacy directive.
  • The EU directive on the taking up, pursuit and prudential supervision of the business of electronic money institutions is implemented in Germany via the law for the implementation of the electronic money directive.
  • The SEPA regulation defines requirements for credit transfers and direct debits along with the time frame for the implementation.
  • The regulation for cross-border payments stipulates that the costs for cross-border payments in euro must not exceed the costs of a domestic payment. This regulation applies to credit transfers and direct debits.
  • The bank account package directive regulates the access to bank accounts and gives every consumer the right to use the basic functions of a basic account. Additionally, customer mobility is legally regulated for bank accounts and fees are made comparable.
  • The amended money transfer regulation consolidates the obligations of intermediary institutions.
  • The fourth money laundering directive and the proposal for changing the fourth money laundering directive to prevent the use of the financial system for money laundering purposes and for financing terrorism.

A look into the future

EU directives and regulations contain defined checking clauses. They prescribe a date by which the European Commission must provide a report on the implementation and effect of the respective directive. This can result in changes to the corresponding directives and regulations.

The following checking periods have been named:

  • Payment Services Directive II: 12 January 2021
  • Directive for interbank fees (MIF Directive): 9 June 2019
  • Bank account package directive: 18 September 2019
  • SEPA regulation: 1 February 2017

Our services

PPI has a wide range of references and project experience relating to the regulatory aspects of payments. We work together with you to identify the effects of the respective rule and implement the corresponding requirements.

Regulation is more than just the obligations. We also support you with the voluntary aspects. See regulation as an opportunity and use it to move your business forward.

  • Our regulatory quick checks provide valuable information fast and precisely in relation to the scope of the changes to come.
  • Our Navigators© identify the affected actors and addressees comprehensively and quickly, along with the changes required.
  • Workshops on individual topics delve into individual aspects of regulation, e.g. business policy opportunities.
  • Our preliminary studies provide specific, useful results for the implementation.
  • During the implementation, our customers value our uncomplicated working methods, our high quality and our strict adherence to schedules and budgets.