The European Association of Co-operative Banks (EACB) welcomes the opportunity to contribute to the Commission consultation on a retail payments strategy for the EU. Indeed, together with the other Credit Sector Associations, it had already delivered a paper outlining “PAYMENTS POLICY FOR EUROPE: DIRECTION FOR THE NEXT FIVE YEARS”. The messages outlined in this paper can also be found back in the EACB answer to the Commission consultation and can be summarised as follows:
EU decision-makers have underlined payments as an area of political importance that is expected to contribute to strengthening the international role of the euro and improving the sovereignty of Europe vis-a-vis global competitors. EACB members share the view of the strategic value of the payments market and the urgent need for action. This action however needs a coherent strategy on an Integrated EU Payments Market.
They consider that the following aspects are essential parts of such strategy to ensure the success of the European Union in the area of payments:
- Instant payments are the basis: there is a need to promote a European payment initiative that is globally recognised and that allows for both the differentiation of EU companies and the reduction of dependency on a small number of dominant providers. This move requires full alignment of industry efforts with full support from EU authorities underpinned by a clear business model. The industry is committed to delivering the basic underlying infrastructure for instant payments as a basis for innovative payment solutions taking into account the new challenges for control and quality checks that the immediate execution of payments brings along.
- Reaping the full benefits of PSD2 and beyond: the full benefits of 'open payments' beyond PSD2 and further expansion of data sharing can only be reaped if done on the basis of mutual benefits and a fair distribution of value across market players. It is important that financial services are not considered in isolation and that data sharing is not limited to financial services. Payment aspects beyond PSD2 should be developed through a coordinated market-driven initiative establishing a SEPA API access scheme.
- Balancing digitalisation and inclusion: The banking industry is keen to innovate in the digital space in order to meet evolving end-user needs but also to serve all customers irrespective of their digital abilities to ensure financial inclusion. It is important that banks are able to innovate and compete with other (non-bank, fully digital) players on an equal footing. Banks still assume responsibility on some societally important functions such as cash provision, deposit accounts and payment accounts availability among others. This calls for a debate about how to balance the costs of those functions with the need to ensure inclusion and access.
- Digital Currencies: EACB members support the EU in trying to define a common approach on crypto- assets and digital currencies while preserving the stability and integrity of our financial system. Any initiatives from central banks should be carefully considered and discussed with the industry.
- A stable regulatory environment: Payment services in the EU are highly regulated. The current regulatory framework guarantees adequate customer protection, promotes competition and innovation and provides a coherent EU single market for payments. Regulators should balance their choices and initiatives when requiring investments from the banking industry. They must carefully consider and prioritise regulatory interventions, taking into consideration the need to support European competitiveness.