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European Payment Institutions Federation

EPIF

The European Payment Institutions Federation (EPIF) was created in July 2011 to represent the interests of the non-banking Payment Institutions at the European level, bringing together a broad range of members and creating the key link between the non-bank payment sector and European regulators.

Lobbying Activity

Meeting with John Berrigan (Director-General Financial Stability, Financial Services and Capital Markets Union) and Afore Consulting

14 Nov 2022 · Instant payments, the digital euro and Open Finance

Response to Revision of EU rules on Anti-Money Laundering (new instrument)

15 Nov 2021

EPIF very much welcomes the Commission’s proposals as part of the AML package. We have been strong supporters of moving to greater harmonization in the EU Anti-Money Laundering (AML) framework and we very much welcome the fact that parts of the Directives have been turned into a maximum harmonization Regulation. EPIF welcomes greater harmonisation on several areas such as: • Reduce reporting burden by streamlining technology and the data elements, as well as standardizing the reporting framework. EPIF welcomes the clearer rules on how reportable transactions are to be identified. EPIF looks forward to the AMLA draft implementing technical standards specifying a common template for the reporting of suspicious transactions to be used as a uniform basis throughout the EU. Having a more effective functioning of the FIUs’ analytical activities and cooperation is key to ensure the efficiency of the system. • Clarifications and additional details regarding CDD. EPIF also supports building and implementing harmonising CDD procedures and a move from paper-based Know-Your-Customer (KYC) to online and innovative on-boarding and KYC solutions building on e-ID are key for EPIF members. • Provisions clarifying the conditions that apply to the processing of certain categories of personal data of a more sensitive nature by obliged entities. EPIF has been calling for clarifications to create legal certainty around the application of the GDPR. While supporting greater harmonisation, standardisation and clarity to enable financial firms to better tackle financial crime across the EU, EPIF would however like to stress the importance of retaining room for a risk-based approach and avoiding becoming overly prescriptive in the requirements firms must apply. EPIF is convinced that its members are best placed to assess the risk of their customer relationships and to take the most appropriate decisions regarding how to best mitigate this risk. EPIF also supports actions to facilitate information exchange between the FIUs, between the obliged entities and the public sector, as well as between private sector obliged entities and the FIUs, and we see the provisions that require the AMLA to develop common reporting templates and practices for Suspicious Transaction Reports/Suspicious Activity Reports (“STR/SAR”) as a very positive progress. Common reports and templates will result in more effective reporting and increased efficiency in the fight against Money Laundering. We would like to add that promoting the use and development of new technologies that can build on these common templates and reduce barriers to entry to new companies and costs to the consumer would be very beneficial. Furthermore, EPIF also welcomes the consultation that has been published on the guidance on public-private partnerships (PPPs). We support the development of PPPs and note that, in order to achieve this goal, more specific rules on the obligation for FIUs to provide feedback to obliged entities must be put in place as well as promoting the sharing of good practices. With regard to the EU Supervisory body, EPIF recommends not to make a debate onnew institutional arrangements in the EU at the expense of effective progress on the above priorities. This, or any, debate should not be allowed to distract from the effective progress on harmonisation. Please see the remaining position in the attached file.
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Meeting with Nathalie De Basaldua (Cabinet of Commissioner Mairead Mcguinness)

28 Sept 2021 · General discussion on AML package

Response to Instant Payments

7 Apr 2021

EPIF welcomes the opportunity to provide our views to the Commission Inception Impact Assessment on Instant Payments. We would like to take this opportunity to share with you some general comments that our members have on this issue. We agree with the Commission’s overall objective to foster pan-European market initiatives based on instant payments, which would ensure that anyone holding a payment account in the EU could be able to receive and send an instant credit transfer from and to any other payment account in the EU. EPIF fully supports the initiatives by the EU towards instant payments. Instant payments open opportunities for payment initiation and acquiring in particular. It also allows for the development of APIs and other payment arrangement services, especially in the area of guarantees and new customer products, such as phased payment solutions, small-scale payments etc. Please find attached our response to the Commission Inception Impact Assessment on Instant Payments
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Response to European Digital Identity (EUid)

3 Sept 2020

EPIF welcomes the opportunity to comment on the Commission’s Inception Impact Assessment on the Revision of the eIDAS Regulation aimed at improving its effectiveness, extend its application to the private sector and promote trusted digital identities for all Europeans. EPIF welcomes the Commission’s position that universally accepted public electronic identity (eID) is necessary for consumers and businesses to have access to their data and securely use the products and services they want without having to use unrelated platforms to do so and unnecessarily sharing personal data with them and agrees that European digital identity that allows for a simple, trusted, secure and accessible to all public system for citizens and businesses to identify themselves and share identity related information in the digital space can be designed efficiently only at EU level. Despite the eIDAS framework, the national rules on provision of digital identity services remain fragmented in or undeveloped across the EU. It is important that the EU sets the right regulatory framework to make sure that the Single Market is fit for the digital age and fosters the development of digital players. EPIF is fully supportive of having Pan-European e-identification mechanisms that are secure, reliable, user-friendly and interoperable and welcome the work of the Commission on this area. EPIF’s preferred policy option would be to introduce a European Digital Identity scheme (EUid) complementary with eIDAS. We would also support option three, to extend the scope of eID regulation under eIDAS to the private sector. Please find full response in the attached document.
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Response to Exchange of VAT-relevant payment data

6 Feb 2019

Please see the attached file for the complete feedback of EPIF. EPIF supports the efforts of the European Commission and National Tax Administrations to tackle VAT fraud and fully understands the desire to capture information from institutions operating as Payment Service Providers (PSP’s) to assist in this process, as with the April 2018 EPIF response to the EC consultation on Exchange of Data to combat VAT fraud. EPIF has concerns with the proposal in its current form around: • Proportionality • Suitability for intended purpose • Overall feasibility and risk of unintended consequences • High cost of development and very significant ongoing cost & effort for PSP’s • Capture of extremely large volumes of data • Unworkably short proposed timeframe for data submission • Certain assumptions upon which key aspects of the proposal rely We believe that the way highly complex elements of payment systems that are interdependent (but often operated by independent parties) operate has not been fully appreciated, especially in terms of the practical difficulty of delivering the full level of data transparency the proposal seeks to achieve, in particular the location of the Payer PSP’s can deliver meaningful levels of data to assist the European Commission and National Tax Authorities in their efforts to combat VAT fraud and set out what we see as being proportionate, achievable and deliverable within the stated policy objectives. Data The highly complex, interactive, fragmented and rapidly evolving nature of the banking and payments industry leads to a situation where no one participant may possess or be able to access of all of the data envisaged by the proposal. Given the very clear presumption that PSP’s will be only providing “…records of data that are already at their disposal…” we do not consider this has been fully understood, particularly in the context of determining the location of the Payer as discussed below. Even in the simple case of the VAT number of a Payee, it may be held by a PSP, but not in the context of any extant payment processing system. Thus it may be “available” in the broadest sense but not always “at their disposal” without some very considerable effort, possibly extensive reconfiguration of systems or new builds. Data Security and Privacy We also need to further consider the interaction of this proposal with Data Privacy Issues, GDPR etc. especially as some aspects appear to require a PSP in some cases to source or transmit sensitive data outside of the EU or EEA. Timescale for Data Submission Transmission to National Tax Authority is expected within 10 days, transmission to CESOP with 15 days. This is simply not credible, reasonable nor proportionate. In our view, based upon the existing UK & Irish domestic Merchant Data Reporting obligations of EPIF members, what is being dealt with are very large, complex data sets which need to be extracted, formatted, cleansed and validated followed by transmission in a secure format, which of itself presents significant operational and security challenges for both the PSP reporting and the recipient national tax authority. Data Analytics teams within PSP’s are a finite resource and always very busy immediately post Quarter ends, so this requirement represents a very significant extra burden with both resourcing and cost implications. We doubt that National Tax Administrations, upon whom all Audit & Control of VAT Fraud rests, have the capacity to make practical use of delivery of data within such a short timeframe. We therefore question if there is any real need for or benefit of such short deadlines for data submission for the actual purpose of combatting VAT Fraud. These deadlines must be very significantly extended. Domestic Payments Reporting Only cross-border transactions are in scope. However, the UK and Ireland have their own domestic Merchant Data Reporting mechanisms for PSP’s.
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Response to Review of Regulation on cross-border payments

12 Jun 2018

Please find attached EPIF's position paper.
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Meeting with Jack Schickler (Cabinet of Commissioner Julian King)

8 Nov 2017 · Terrorist financing and cybersecurity

Meeting with Markus Schulte (Cabinet of Vice-President Günther Oettinger)

3 Feb 2017 · Payment services Directive

Meeting with Chantal Hughes (Cabinet of Commissioner Julian King)

8 Nov 2016 · Fintech and cybersecurity