The EACB welcomes the opportunity to participate in the public consultation on Draft Guidelines on the information to be provided for the authorisation as payment institutions and e-money institutions and for the registration as account information service providers. The EACB believes that the environment in which PSD2 will be implemented is an increasingly complex ecosystem full of diverse payment services providers. These Guidelines should aim at bringing further clarity to this environment thought the definition of clear requirements that third party providers have to fulfilled to obtain their authorisation or registration. Ultimately, the Guidelines should serve as an instrument to counter the many uncertain effects of the new PSD2 liability regime on market players. In this context, the EACB would like to stress the following points:
- The process thought which credit institutions might offer account information and payment initiation services should be clarified;
- The Guidelines should address in greater detail the update of the information/documentation provided by applicants;
- The link between these Guidelines and the Guidelines on the criteria on how to stipulate the minimum monetary amount for professional indemnity insurance should be more clearly defined;
- Requirements on the information to be provided by applicants about data processing practices should be defined consistently with both related PSD2 provisions and its level 2 acts which are currently under development
