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European Third Party Providers Association

ETPPA

ETPPA represents the interests of third party providers of payment services (TPPs) independent of incumbents, arising out of PSD2 (Directive (EU) 2015/2366), but is open to all TPPs from all industries.

Lobbying Activity

Meeting with Eric Ducoulombier (Acting Director Financial Stability, Financial Services and Capital Markets Union)

15 Jan 2026 · Exchange of views on open banking

Meeting with Eric Ducoulombier (Acting Director Financial Stability, Financial Services and Capital Markets Union)

30 Sept 2025 · PSR negotiations

Meeting with Maria Luís Albuquerque (Commissioner) and

20 Mar 2025 · ETPPA presented their main concerns on digital finance and payment files

Response to EU Start-up and Scale-up Strategy

16 Mar 2025

ETPPA agrees wholeheartedly that startups and/or scaleups face the hurdles identified in the European Commissions call for evidence on startups and scaleups. In particular, ETPPA would focus on i) regulatory and bureaucratic burdens; and ii) the fragmentation of the EUs regulatory landscape in different policy areas (please note we also raise additional hurdles in response to question 2 below, which are faced by startups and scaleups in the fintech landscape). ETPPA would also agree that differences in national regulatory regimes may also discourage investors that are less likely to invest in companies based in another Member State. A good example would the EUs second payment services directive - PSD2, which has seen a lot of fragmentation resulting as a result of i) being a directive, rather than a regulation; ii) the level one legislative text leaving too much to be prescribed by level two and three legislation and policy e.g. Regulatory Technical Standards by the European Banking Authority. Regulatory and bureaucratic burdens and fragmentation are something third party providers (TPPs) and other fintechs experience on an ongoing basis. Below we provide a (non-exhaustive) list of examples of regulatory/ bureaucratic burdens and fragmentation experienced by TPPs specifically PSD2 lessons to avoid illogical regulatory hurdles for fintech startups and scaleups The EU wants to foster EU champions in payments to challenge payment service providers from the US and China. The EUs second Payment Services Directive (PSD2) aimed to increase competition and security and drive innovation in the EU payment services sector. Whilst the level 1 text of PSD2 was a very good basis for this, the level 2 and level 3 legislation and guidance have dramatically shifted the goal posts from what was laid out in PSD2, to the point of going against the very spirit of the level 1 text. Please find attached ETPPA's feedback to the call for evidence.
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Response to Open finance framework

31 Oct 2023

For several years, ETPPA has contributed to the European Commissions work in the Financial Data Access arena by participating in its Financial Data Space Expert Group, its Open Finance report and providing feedback to its targeted consultation. We are pleased that some of our recommendations were adopted into the FIDA proposal published on June 28, which has great potential for a move from open banking to open finance more broadly in Europe. Unfortunately, some of our most critical recommendations are not part of the proposed text, and we hope the co-legislators will be willing to recommend their inclusion. For that, we would like to list these points in our attached position paper, including the rationale for why they are required to enable financial services customers to take control over their data and thereby getting access to a wider range of competitive and innovative services across Europe.
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Response to Payment services – revision of EU rules (new Regulation)

31 Oct 2023

ETPPA has contributed heavily to the European Commissions review of PSD2, and we are pleased to see that some of our recommendations have been reflected in the proposed package published on June 28. ETPPA strongly supports the Commissions proposal to review PSD2 and is pleased to see the Commissions vision to reaffirm open banking in Europe. Moving many parts of the directive into a regulation is a positive development, which will hopefully remove much of the fragmentation we have seen across the EU. We particularly welcome the PSRs focus on improving APIs by increasing the enforcement of existing law, mandating more functionalities, maintaining PSD2s non-contractual obligation and non-charge provision for TPP access to payment account data and prohibiting obstacles. Also, being fully committed to fraud prevention, ETPPA welcomes the new provisions allowing the exchange of information for that purpose. That said, some of our most critical recommendations are not part of the proposed text, and we hope the co-legislators will be willing to recommend their inclusion in order to ensure PSR strikes the right balance to foster competition and innovation in the EU. In our attached position paper we list these points and the rationale for why they are required in the interest of consumers, merchants, competition and innovation in the European Retail Payments arena.
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Meeting with Marek Belka (Member of the European Parliament, Rapporteur)

28 Sept 2023 · Payment Services Regulation (APA on behalf of MEP)

Response to Establishing the digital euro

8 Sept 2023

Position Summary Over the past years, ETPPA has contributed to the regular technical and dedicated industry association sessions of the ECBs Digital Euro Project Team and its scheme rulebook development group. Additionally, ETPPA has provided feedback to the European Commissions stakeholder consultation on a digital euro in June 2022 (https://drive.google.com/file/d/1hkWc-mHn-izOyFcGF6pP89RB2MOaQ9yt/view?usp=sharing). ETPPA welcomes the Digital Euro proposal published on June 28, which comes at an exciting time for the EUs regulatory landscape of payments. Importantly, the proposal clarifies that any account-based digital euro would fall under PSD2 and therefore be accessible to TPPs as any other online payment account. The proposal equally mandates an offline version right from the start, which is likely to be more popular, and which will allow bank and non-bank PSPs to compete on a more level playing field. Our biggest concerns in relation to the latest design choices being proposed for the digital euro are the foreseeable disruption of the retail payments ecosystem, the missing incentives for intermediaries to drive the use of a Digital Euro and the number of use cases being considered for launch. The role of acquirers, and that of PISPs in particular, appear to be limited, which may jeopardise the suggested compensation model. Suggested additions to the Digital Euro proposal ETPPA believes that the ECBs monetary policy objectives should not be the only, and not even the most decisive factors in designing the Digital Euro. Acceptance by payers and payees as well as the whole financial services ecosystem should prevail and define at least the initial basic principles, which can then be fine-tuned to ensure that the most important monetary policies are also respected. To this effect, we believe that the following points need to be considered by the co-legislators, and reflected in the final text. 1. Focus on digital cash, i.e. tokens in a wallet 2. Anonymous up to legal limits 3. Maximise usability, including offline use, and avoid any unnecessary friction 4. Maximise accessibility and payment handling via APIs to enable value-added services by TPPs 5. Bundled with EU Digital Wallets if and when available For more details on these 5 points please see our attached position paper.
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Meeting with Mairead McGuinness (Commissioner) and

28 Mar 2023 · Round-Table on Digital Euro (with EVP Dombrovskis and DG FISMA)

Response to Instant Payments

3 Jan 2023

ETPPA welcomes the European Commissions legislative proposal for a regulation on instant payments. A regulation to secure the wide-spread availability of instant payments has long been a missing brick in the PSD2 ecosystem. We believe there has been a clear need for swift legislation in order to help payment initiation service providers (PISPs) and other payment service providers (PSPs) in general leverage the huge investments already made into PSD2 infrastructure on open banking. The availability of instant payments for all consumers in making outgoing SEPA Instant Credit Transfer (SCT Inst) payments is an underlying necessity for achieving home-grown and pan-European payment solutions. ETPPA believes that all account servicing payment service providers (ASPSPs) offering non-instant SCT today should be mandated to offer SCT Inst in an equal form and without any premium fees. Knowing that SCT Inst has not found widespread adoption across EU Member States despite the SEPA schemes self-regulatory stipulation, this must now be enforced by legislation so that its benefits are made available to EU consumers without any further delay. ETPPA calls on the co-legislators to support this mandate and to ensure the certainty of instant payments, thereby future proofing the EUs retail payments market so that it can compete globally. That said, there are six important areas where improvements to the legal text are needed in order to create an optimal outcome for all EU consumers and businesses. 1. Payee IBAN and name matching - also known as Confirmation of Payee (CoP) - will have a negative impact on payer experiences. (Article 5c) We appreciate the need to tackle authorised push payment (APP) fraud, but CoP is not the right tool for that. There is no compelling evidence that CoP reduces or prevents fraudulent transactions, and we fear that instead this requirement will open the Pandora's box. Experience from other markets (e.g. UK where CoP only corrects misdirected payments and Sweden where an attempted CoP rollout was aborted) demonstrates that CoP is incredibly difficult to implement and does not tackle APP fraud. Instead, we find that CoP: adds friction to the payment experience; conditions payers to click away information boxes (like cookie requests) scares users away from using credit transfer payment services; enables surcharges for payers using CoP; creates incentives for continuing the use of non-instant SCT (not requiring CoP). 2. Missing provision - the proposed Instant Payments Regulation should oblige PSPs to notify the payee, the payer, and the initiating party if different (e.g. a PISP) of a successful or failed instant payment in real-time and free of charge (Article 5a) To ensure that account-based instant payments can become a competitive alternative to traditional (card-based) payments, the regulation should allow participants to benefit from a consistent approach to payment confirmations providing instant certainty. Currently, there is one-way communication from a PISP to the payers ASPSP in the payment initiation process. The ASPSP is not required to confirm that the payment has been accepted and is being executed. This means that consumers and businesses do not enjoy payment certainty when using payment initiation services. 3. Price of SCT Inst - there must be legal protections to avoid ASPSPs increasing fees for SCT so that they can charge more for SCT Inst (Article 5b) 4. Settlement finality - the proposed Instant Payments Regulation should include a provision to amend the Settlement Finality Directive (SFD) 5. Reimbursements - ensuring the possibility for refunding an SCT Inst without the need for SCA 6. Timing - ensure swift adoption of Instant Payments Regulation and do not repeat the timing mistakes from PSD2 and SEPA (Article 5a)
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Response to Revision of EU rules on Anti-Money Laundering (new instrument)

16 Nov 2021

ETPPA believes that additional amendments and clarifications are necessary in order to ensure that third party payment service providers (“TPPs”) are afforded a fair environment for competing with other payment options and payment service providers, in particular card-based payments. To that end, the ETPPA proposes ​​that account information service providers (“AISPs”) and payment initiation service providers (“PISPs”) should be excluded from the AML Regulation and should instead be subject to a more limited range of AML/CFT rules, which govern primarily the investigation of suspicious transactions. This is similar to a UK Government proposal, which is currently being consulted on. We proposed not to include AISPs and PISPs into the scope of AML rules when PSD2 was created. Since then the European Supervisory Authorities (“ESAs”), namely the European Banking Authority (“EBA”), have recognized and highlighted that “AISPs are not involved in the payment chain and do not hold customer funds”, and “PISPs do not themselves execute the payment transactions or any transfer of funds or enter into the possession of the payment service user’s funds”. In their view, PISPs and AISPs have a “low inherent risk” and should therefore only be subject to Simplified Due Diligence (SDD) obligations. As PISPs and AISPs are only providers of software tools, formerly correctly categorized as “technical service providers” in Art. 3 lit (j) PSD1 (Directive 2007/64/EC), we continue to believe their treatment as “financial institution” is incorrect. They do not hold or handle funds and therefore do not conduct any “financial activity”. We agree with the EBA and the other ESAs that, in any event, only SDD should apply, and we agree with the national authorities that have exempted AISPs from the current AML Directive under Art. 2(3) (Directive 2015/849), referring to the fact that AISPs have no financial activity. However, we still think that TPPs do not constitute, and should not be treated as, “financial institutions” in the first place. Despite that fundamental dissent, as long as AISPs and PISPs are being treated as obliged entities under the AML Regulation, the ETPPA proposes the following: - It should be highlighted that AISPs and PISPs are eligible for exemptions under Art. 5 (1) AML Regulation to the extent they do not conduct any material financial activities. - It should be highlighted that AISPs and PISPs are entitled to SDD under Art. 27 AML Regulation, and that they should as a rule be granted SDD, because of their inherently low risk. - Recital 34 of the AML Regulation should be clarified to avoid any doubt that the confirmation therein remains valid where a payer uses a PISP’s services more than once to initiate payments to the merchant. - It should be clarified in Recital 34 of the AML Regulation that merchant-serving PISPs do not carry out occasional transactions for the merchants’ customers. - It should be clarified that AISPs are never involved in and never carry out occasional transactions in the meaning of the AML Regulation.
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Meeting with Agnieszka Drzewoska (Cabinet of Commissioner Mairead Mcguinness)

20 Oct 2021 · Instant payments, TTPs business environment.

Response to Instant Payments

7 Apr 2021

ETPPA, the European trade association of bank-independent Third Party Providers (TPPs) under PSD2, very much welcomes the EC’s initiative in promoting instant payments and its Inception Impact Assessment, which we hereby would like to comment on: We fully agree that instant payments shall become the new normal and agree to the EC’s Retail Payments Strategy supporting this objective. The full availability of instant payments for all consumers in the form of their ability in making outgoing SCT Inst payments is an underlying necessity for that and we therefore believe that all retail consumer banks, which are offering SCT today, should be mandated to offer SCT Inst in an equal form and at the same price. Outgoing SCTs are usually debited instantly, whilst incoming transfers are credited the next day, which is particularly disadvantageous to consumers and SMEs. SCT Inst will bring this to an end and it will also give payers an additional payment instrument, which will be less costly than the handling of cash, and more available and possibly cheaper than cards. PISPs stand ready to leverage the superior functionalities of SCT Inst and their huge investments into PSD2-related API infrastructure and connections. Their much lower non-execution risk vs. SCT initiations is likely to lead to a significant growth of PIS across Europe. Only the legislative option can lead to SCT Inst adoption in the time and to the extend required for the European retail payments market to catch up and get ahead of the developments in other regions of the world. For that we are supporting legislative action for the following four measures on your list of considerations: - effective incentives for PSPs to offer SCT Inst similar to SCT and SDD - addressing the issue of charges levied on consumers for instant credit transfers - exploring issues regarding fee structures for SCT Inst-based payment solutions - ensuring sound mitigation measures on the liquidity risk The required interoperability and standardization work is already on its way via ERPB and EPC multi-stakeholder groups and the required fraud protection appears possible within the existing and already rather broad ranging legislation. As with any new form of payment instruments, consumer protection must be a particular concern. Thankfully, we can look at two decades of experience with principally equivalent SCT-based payment methods in several member states and their best in class track record in comparison to any other payment method from a consumer point of view. The intrinsic advantages of push over pull payments in combination with the consequent application of Strong Customer Authentication (SCA) has ensured far lower fraud levels compared to card payments. Disputed transactions must be handled according to existing legislation and not by introducing unilateral chargeback rights of buyers mimicking the outdated legacy of card payments caused by their increased risk and inefficiencies. Any buyer protection above the legal standard must remain a commercial activity allowing competition and the possibility to use superior technology in providing higher protection at a lower cost. Contrary to cards or direct debits, SCT and SCT Inst-based payments cannot be initiated by payees themselves and they cannot be executed without the payer’s authorization, incl. when a PISP is involved. Also important to note: SCT Inst does not increase buyer risk in terms of “cancellation” or “reversibility” in comparison to SCTs, because SCTs are also instantly debited from the payer’s account. It does add a buyer benefit though: goods are released instantly, because merchants get the credit instantly and without having to pay an interchange fee for that. In conclusion, we recommend legislative action as soon as possible to mandate the adherence to SCT Inst for all current and future adherents of SCT and as a minimum, the subset of these servicing consumer (retail) payment accounts.
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Meeting with Agnieszka Drzewoska (Cabinet of Commissioner Mairead Mcguinness), Florian Denis (Cabinet of Commissioner Mairead Mcguinness)

24 Mar 2021 · Retail payments services, digital finance

Meeting with Mairead McGuinness (Commissioner)

8 Mar 2021 · Payment Services.