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Mastercard Europe

Mastercard is a global payments technology company that enables electronic transactions between consumers, financial institutions, and merchants worldwide.

Lobbying Activity

Meeting with Gert Jan Koopman (Director-General Enlargement and Eastern Neighbourhood)

9 Jan 2026 · Mastercard Europe requested a meeting to share developments from Mastercard in the ENEST region

Meeting with Victor Negrescu (Member of the European Parliament)

20 Nov 2025 · Preparation of Mastercard Strive Event

Meeting with Auke Zijlstra (Member of the European Parliament, Shadow rapporteur)

16 Oct 2025 · Digital euro

Meeting with Maria Zafra Saura (Cabinet of Commissioner Michael McGrath)

15 Oct 2025 · Data protection

Mastercard urges streamlined cybersecurity reporting across EU digital rules

14 Oct 2025
Topic — EU proposal to simplify digital regulations including data, AI, cybersecurity and ePrivacy rules.
Message — Mastercard requests harmonized cybersecurity incident reporting with once-only reporting to a single authority. They want SIPS excluded from DORA scope and clearer AI data processing rules under GDPR.1234
Why — This would reduce duplicative compliance paperwork and allow resources to focus on incident response.56
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Meeting with Mattias Levin (Acting Head of Unit Financial Stability, Financial Services and Capital Markets Union)

10 Oct 2025 · Brief discussion of outstanding issues in proposed framework for financial data access in light of ongoing interinstitutional negotiations with a particular focus on fraud protection.

Meeting with Victor Negrescu (Member of the European Parliament)

17 Sept 2025 · Impact CEE Bucharest 2025

Response to Digital services for simplifying business operations and reducing administrative costs – the business wallet

12 Jun 2025

Mastercard welcomes the opportunity to provide comments to this consultation. Please find our response attached.
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Meeting with Eric Ducoulombier (Acting Director Financial Stability, Financial Services and Capital Markets Union) and

12 Jun 2025 · Courtesy visit

Meeting with Ioan-Dragos Tudorache (Cabinet of Executive Vice-President Stéphane Séjourné)

12 Jun 2025 · E-commerce and AI policy in the EU

Meeting with Ioana-Maria Gligor (Head of Unit Secretariat-General)

10 Jun 2025 · Exchange of views on EU digital policy

Meeting with Michael McGrath (Commissioner) and

20 May 2025 · Exchange on simplification, data protection and online fraud prevention

Meeting with Valdis Dombrovskis (Commissioner) and

19 May 2025 · Digital euro

Meeting with Niels Flemming Hansen (Member of the European Parliament)

14 May 2025 · Roadmap to more competitive European SMEs

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

8 May 2025 · Discussed innovative, evolving retail payments

Meeting with Fernando Navarrete Rojas (Member of the European Parliament, Rapporteur) and EPI Company

2 May 2025 · Euro Digital

Meeting with Isabel Benjumea Benjumea (Member of the European Parliament)

24 Apr 2025 · ECON

Meeting with Jonás Fernández (Member of the European Parliament)

24 Apr 2025 · Economic priorities and digital euro

Meeting with Pablo Arias Echeverría (Member of the European Parliament)

24 Apr 2025 · Electronic payments, Data protection, and Cybersecurity

Meeting with Stephen Nikola Bartulica (Member of the European Parliament)

8 Apr 2025 · Digital euro

Meeting with Arba Kokalari (Member of the European Parliament, Rapporteur)

27 Mar 2025 · AI in Financial Services

Meeting with Denis Nesci (Member of the European Parliament) and Cattaneo Zanetto Pomposo Co.

26 Mar 2025 · Eurodigitale e turismo

Meeting with Mattias Levin (Acting Head of Unit Financial Stability, Financial Services and Capital Markets Union)

25 Mar 2025 · Discussion on the Financial Information Data Access proposal (FIDA) and the AI framework

Meeting with Pasquale Tridico (Member of the European Parliament)

25 Mar 2025 · Meeting with Mastercard

Meeting with Eric Ducoulombier (Head of Unit Financial Stability, Financial Services and Capital Markets Union)

6 Mar 2025 · General catch-up on payments priorities and files

Meeting with Kinga Kollár (Member of the European Parliament)

5 Mar 2025 · payment service legislation (PSD3/PSR)

Meeting with Alice Guedel (Cabinet of Commissioner Maria Luís Albuquerque), Cristina Dias (Cabinet of Commissioner Maria Luís Albuquerque)

5 Mar 2025 · Mastercard Europe presented their company and activities, sharing an overview of the different services they offer.

Meeting with Hubert Gambs (Deputy Director-General Internal Market, Industry, Entrepreneurship and SMEs)

18 Feb 2025 · Presentation of Mastercard’s activities with a view to SMEs and potential link to the work of the European Commission

Meeting with Antti Timonen (Cabinet of Executive Vice-President Henna Virkkunen), Marlene Rosemarie Madsen (Cabinet of Executive Vice-President Henna Virkkunen)

18 Feb 2025 · Competitiveness and cybersecurity and digital agenda in the European Union

Meeting with Judit Rozsa (null Structural Reform Support)

17 Feb 2025 · Digitalisation of Public Administration in Europe

Meeting with Dirk Gotink (Member of the European Parliament)

17 Feb 2025 · Digital Euro and payment regulation

Meeting with Despina Spanou (Principal Adviser Communications Networks, Content and Technology)

14 Feb 2025 · Meeting in the margins of the Munich Cyber Security Conference on EU cybersecurity priorities and the role of public-private partnerships.

Mastercard urges harmonised standards and public-private security partnerships

31 Jan 2025
Topic — The consultation seeks to remove regulatory barriers and enhance European single market competitiveness.
Message — Mastercard requests a unified legislative framework to prevent market fragmentation and support cross-border business. They advocate for public-private partnerships to combat cybercrime and increased investment in citizens' digital skills.123
Why — Consistent rules across borders reduce the complexity and cost of operating their global payment network.45
Impact — Local providers may face tougher competition as cross-border barriers protecting national markets are removed.67
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Meeting with Niels Flemming Hansen (Member of the European Parliament)

27 Jan 2025 · Priorities for the mandate

Meeting with Filippo Terruso (Cabinet of Commissioner Apostolos Tzitzikostas)

23 Jan 2025 · Presentation by Mastercard of their activity in data collection and cooperation with Destinations for flow management, digitalisation of SMEs (Tourism Innovation hub). Presentation of their Mobility Innovation Hub

Meeting with Egelyn Braun (Cabinet of Commissioner Michael McGrath), Fiona Knab-Lunny (Cabinet of Commissioner Michael McGrath)

15 Jan 2025 · Exchange of views on the agenda of the European Commission, especially regarding the upcoming Digital Fairness Act and the consumer agenda

Meeting with Michalis Hadjipantela (Member of the European Parliament)

27 Nov 2024 · Meeting with Mastercard

Meeting with Gilles Boyer (Member of the European Parliament, Shadow rapporteur)

27 Nov 2024 · Digital euro

Meeting with Zala Tomašič (Member of the European Parliament)

27 Nov 2024 · Digitalization and cybersecurity

Meeting with Hanna Gronkiewicz-Waltz (Member of the European Parliament)

27 Nov 2024 · payment services market in Europe

Meeting with Sunčana Glavak (Member of the European Parliament)

27 Nov 2024 · Hybrid threats, cyber threats, challenges related to organized crime, aspects of financial fraud and money laundering, education

Meeting with Davor Ivo Stier (Member of the European Parliament)

27 Nov 2024 · Countering hybrid threats and challenges in the field of cyber security

Meeting with Eszter Lakos (Member of the European Parliament)

27 Nov 2024 · Digital policy

Meeting with Vasile Dîncu (Member of the European Parliament)

27 Nov 2024 · Improving Romanian tax policy

Meeting with Arba Kokalari (Member of the European Parliament)

27 Nov 2024 · Digital policy

Meeting with Kristian Vigenin (Member of the European Parliament)

27 Nov 2024 · State of play and future initiatives

Meeting with Stéphanie Yon-Courtin (Member of the European Parliament)

27 Nov 2024 · Payments / Competitiveness

Meeting with Ondřej Krutílek (Member of the European Parliament)

27 Nov 2024 · Innovation in digital sector and EU legislative

Meeting with Morten Løkkegaard (Member of the European Parliament)

27 Nov 2024 · Digital European economy

Meeting with Lukas Mandl (Member of the European Parliament)

27 Nov 2024 · Digital Euro

Meeting with Dirk Gotink (Member of the European Parliament)

27 Nov 2024 · Payment services and digital euro

Meeting with Nikolina Brnjac (Member of the European Parliament)

26 Nov 2024 · Meeting on priorities in area of tourism

Meeting with Victor Negrescu (Member of the European Parliament)

26 Nov 2024 · Competitiveness, innovation and digital transformation

Meeting with Francesco Torselli (Member of the European Parliament)

26 Nov 2024 · Incontro conoscitivo per discutere delle problematiche del sistema dei pagamenti digitali

Meeting with Nicola Zingaretti (Member of the European Parliament)

26 Nov 2024 · digital currency and networks

Mastercard Urges EU Global Collaboration for Digital Infrastructure

30 Jun 2024
Topic — The consultation examines scenarios to improve Europe's digital network rollout and security.
Message — Mastercard calls for infrastructure that supports advanced payments and tokenization to drive growth. They emphasize maintaining international partnerships and adopting a holistic, collaborative approach to cybersecurity.12
Why — Openness to international partners ensures the company can continue leveraging its global network within Europe.3
Impact — Consumer interests may suffer if policies reduce market competition or weaken system resilience.4
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Meeting with Alviina Alametsä (Member of the European Parliament)

27 Jun 2024 · Exchange of views

Meeting with Despina Spanou (Cabinet of Vice-President Margaritis Schinas)

4 Jun 2024 · Cybersecurity, Cybersecurity Skills Academy, opening of Mastercard's first European Cyber Resilience Centre in Waterloo Belgium

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

29 May 2024 · Transition towards a vibrant digital economy through supporting Fintech and harnessing innovation in the payments market.

Meeting with Alfred Sant (Member of the European Parliament)

6 Mar 2024 · Financial data access

Meeting with Michiel Hoogeveen (Member of the European Parliament, Shadow rapporteur) and Visa Europe

11 Jan 2024 · Digital euro

Meeting with Jörgen Warborn (Member of the European Parliament) and SME Connect

29 Nov 2023 · Småföretagarfrågor

Meeting with István Ujhelyi (Member of the European Parliament)

29 Nov 2023 · EU Relations

Meeting with Werner Stengg (Cabinet of Vice-President Věra Jourová)

20 Nov 2023 · Fraud prevention and the AI Act, G7 Code of Conduct

Meeting with Eero Heinäluoma (Member of the European Parliament, Shadow rapporteur)

15 Nov 2023 · Framework for Financial Data Access and amending Regulations (EU) No 1093/2010, (EU) No 1094/2010, (EU) No 1095/2010 and (EU) 2022/2554.

Meeting with Nicolo Brignoli (Cabinet of Executive Vice-President Valdis Dombrovskis)

24 Oct 2023 · Economy, digital resilience, digital euro

Meeting with Věra Jourová (Vice-President)

11 Oct 2023 · Approach to GDPR and Data Responsibility, Artificial intelligence act, Mastercard's European footprint

Meeting with Stefan Berger (Member of the European Parliament, Rapporteur)

10 Oct 2023 · Digital Euro

Meeting with Mairead McGuinness (Commissioner) and

10 Oct 2023 · Digital Payments

Meeting with Irene Tinagli (Member of the European Parliament, Committee chair)

21 Sept 2023 · Introductory Meeting

Meeting with Annelisa Cotone (Cabinet of Commissioner Helena Dalli)

20 Sept 2023 · Inclusion and diversity

Meeting with Angelika Winzig (Member of the European Parliament)

18 Sept 2023 · Strive EU

Meeting with Ondřej Kovařík (Member of the European Parliament, Rapporteur) and FTI Consulting Belgium

15 Sept 2023 · PSD III

Response to Establishing the digital euro

8 Sept 2023

Mastercard welcomes the opportunity to share its views on the proposal for a Regulation of the European Parliament and of the Council on the establishment of the digital euro. We believe that the proposal provides an important first step towards developing the basis of a public-private partnership to deliver public money for a new digital age. We appreciate that the European Commission has undergone a thorough assessment of the different design options available, outlining many of these in its comprehensive impact assessment report. However, as currently drafted, the proposal gives rise to problematic trade-offs that, without substantive amendment, will jeopardise the privacy, stability, level playing field and security objectives of the digital euro. In the attached paper, we highlight key areas that give rise to these problematic tensions, and make recommendations on how to navigate these trade-offs.
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Meeting with Mairead McGuinness (Commissioner) and

22 Jun 2023 · Digital Finance

Meeting with Geneviève Tuts (Cabinet of Commissioner Didier Reynders), Lucrezia Busa (Cabinet of Commissioner Didier Reynders)

25 May 2023 · Data protection and AI.

Meeting with Florian Denis (Cabinet of Commissioner Mairead Mcguinness), Patricia Reilly (Cabinet of Commissioner Mairead Mcguinness)

25 May 2023 · payments, digital transformation

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

24 May 2023 · Digital Euro, PSD2 review, and sanctions

Meeting with Daniel Calleja Crespo (Director-General Legal Service)

24 May 2023 · Courtesy visit

Meeting with Roberto Viola (Director-General Communications Networks, Content and Technology)

16 May 2023 · digital transition

Meeting with Valeria Miceli (Cabinet of President Ursula von der Leyen)

11 May 2023 · EU payment system, digital means of payment and the digital euro.

Meeting with Maurits-Jan Prinz (Cabinet of Commissioner Thierry Breton)

11 May 2023 · EU SME policies

Response to Virtual worlds, such as metaverse

3 May 2023

Virtual worlds will be a fast-evolving and complex area with a great many opportunities and challenges. At Mastercard, we understand that harnessing the potential brought by these innovations requires a thoughtful approach, one that can support innovation, while also grounded in trusted, secure and privacy preserving principles. As digital payments are likely to be one of the core technologies enabling the transition towards Web 4.0, Mastercard has prepared several thoughts and questions that we believe will be essential for establishing trust in the next technological transition. Our high-level comments below focus on the three themes of (1) privacy & security, (2) underlying technologies and (3) societal concerns. We stand at the ready to partner with the European Commission as it starts on this journey to the future.
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Meeting with Tsvetelina Penkova (Member of the European Parliament) and Banco Santander, S.A. and Assicurazioni Generali S.p.A

28 Apr 2023 · EUROFI

Meeting with Florian Denis (Cabinet of Commissioner Mairead Mcguinness) and FTI Consulting Belgium

12 Apr 2023 · Digital euro, Crypto finance

Meeting with Simon Genevaz (Cabinet of Executive Vice-President Margrethe Vestager)

23 Mar 2023 · Exchange of views on the European payments landscape and preparing for CEO visit

Meeting with Margaritis Schinas (Vice-President) and

21 Mar 2023 · Ukraine, cyber-resilience and skills, combatting child sexual abuse online

Meeting with Paolo Gentiloni (Commissioner)

21 Mar 2023 · Exchange of views on economic outlook and financial services

Meeting with Helena Dalli (Commissioner) and

21 Mar 2023 · Meeting with Mastercard CEO to discuss Diversity in the workplace

Meeting with Marek Belka (Member of the European Parliament) and Fundacja Polska Bezgotówkowa

24 Feb 2023 · Payments Landscape in Poland + Preparation for the Event on Payments

Meeting with Sabine Weyand (Director-General Trade)

21 Feb 2023 · Trade Policy, digital transition.

Meeting with Mario Nava (Director-General Structural Reform Support)

21 Feb 2023 · Exchange views on digital transition and in particular on financial sector.

Meeting with Birgit Sippel (Member of the European Parliament, Rapporteur)

20 Feb 2023 · e-evidence (Staff-level)

Meeting with Gerassimos Thomas (Director-General Taxation and Customs Union)

2 Feb 2023 · Physical meeting - Introductory meeting and exchange of view on main challenges for tax policy in the EU

Meeting with Alin Mituța (Member of the European Parliament, Shadow rapporteur)

15 Nov 2022 · Data Act

Meeting with Mairead McGuinness (Commissioner) and

27 Sept 2022 · Roundtable on Remittances to Ukraine

Meeting with Valeria Miceli (Cabinet of President Ursula von der Leyen)

19 Jul 2022 · Mastercard explained how they are helping Ukrainian people and companies and how they are implementing Eu sanctions.

Meeting with Thierry Breton (Commissioner) and

15 Jun 2022 · Counterfeiting

Meeting with Alfred Sant (Member of the European Parliament)

22 Apr 2022 · general discussion (cyber, digital, future of payments)

Response to Package travel – review of EU rules

16 Sept 2021

Response to Commission’s Roadmap/Impact Assessment on the Packaged Travel Directive The travel industry represents a clear example of how the pandemic has radically altered the landscape and expectations of all stakeholders of the ecosystem, such as travel agencies, airlines and, of course, consumers. In this context, Mastercard welcomes the review of the Packaged Travel Directive, as it signifies a great opportunity to ensure that all participants in the value-chain are adequately protected, and that the legal framework reflects this changing landscape. As already outlined in the roadmap, the ongoing pandemic is having a massive impact on European citizens who are facing a very difficult situation, particularly in relation to seeking and receiving reimbursement for their cancelled travel plans. At the same time, travel intermediaries, such as travel agencies or tour operators, are facing severe liquidity risks as they are dealing with hundreds or even thousands of such reimbursement requests. Consequently, an important issue that became apparent during the pandemic was not only protecting refunds to the consumers, but also securing the payment from travel intermediaries, as packaged travel organizers, (e.g., travel agents) to travel service providers (e.g., airline, hotel). This is particularly the case when the travel intermediary acts as the Merchant of Record and does not use an open loop card or a secure form of payment to transfer funds to travel service providers. In this context, the review of the Packaged Travel Directive should aim to establish fairer burden-sharing in the value chain through requirements on refunds from travel service providers (e.g., airlines, hotels) to package organizers. This would ensure the existing legal framework remains fit-for-purpose and aligned with emerging realities in the sector and would ultimately also guarantee that consumers are adequately protected when they book their travel package. In the upcoming review of the Packaged Travel Directive, Mastercard supports and encourages the European Commission to introduce measures and rules on refunds from providers of travel services (e.g., airlines, hotels) to package organizers, as outlined in the roadmap under the policy options that are being considered. A complementary avenue to explore is to protect package organizers by introducing rules that would require the payment from package organizers to providers of travel services to be protected in a trust, where the funds will only be transferred once the consumer has acquired the services. As highlighted in our position (attached), the Directive should clarify or introduce rules that would protect the travel intermediary (e.g., travel agency acts as the ‘Merchant of Record’) in regard to reimbursements to the consumer. In cases where the Consumer has purchased the travel service, as part of travel package, from the travel service provider directly, or in the case where the travel intermediary is acting as the ‘booking’ intermediary, then the responsibility for the reimbursement should lie with the travel service providers.
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Response to Requirements for Artificial Intelligence

6 Aug 2021

Mastercard welcomes the opportunity to provide feedback to the European Commission on the Proposal for a Regulation laying down harmonised rules on artificial intelligence. This consultation comes at a difficult moment for many individuals, communities and businesses. Nearly a year and a half into the COVID-19 pandemic, despite breakthrough vaccines, we are still fighting the tragic health implications of the virus and grappling with the new reality of physically distanced and increasingly digital lives. At a moment of increased vulnerability across the economy, AI-based tools, built on a robust governance framework, have helped Mastercard facilitate access to the digital economy, thus increasing trust in our payment network and solutions. Mastercard understands the importance of trust and decency. Clearly the events of the past 18 months have only underscored the need for these values in our lives and business relationships. Mastercard therefore fully supports the creation of a proportionate regulatory framework that will facilitate the uptake of trustworthy AI in the European Union and wishes to respectfully submit its comments on the following main topics: 1. Definitions and scope 2. Remote biometric identification 3. Requirements for high-risk AI systems 4. Enforcement and competent authorities Please find attached our detailed position on those main topics.
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Response to Data Act (including the review of the Directive 96/9/EC on the legal protection of databases)

25 Jun 2021

Mastercard welcomes the opportunity to provide feedback on the Inception Impact Assessment (IIA) of the European Commission’s future Data Act (including the review of the Directive 96/9/EC on the legal protection of databases). Mastercard is supportive of the development of a human-centric data ecosystem which will encourage public entities and business to share and use data in a fair and transparent way. This is fully in line with our Data Responsibility Imperative that guides all our data practices across the organization globally. Mastercard is playing a key role in advancing data science for social good. We are partnering with private sector entities, NGOs, and governments on projects that seek to advance inclusive growth and financial inclusion – including with Harvard University, London School of Economics, Massachusetts Institute of Technology, Stanford University, McGill University, IMF, World Bank, and numerous states and cities. For example, Mastercard’s Center for Inclusive Growth excels at using insights and expertise to help social, civic and government organizations use data driven insights to make a positive impact. We agree with the aims identified in the European Data Strategy, including creating a digital economy that places the interests of the individual first, in accordance with European values, fundamental rights and rules. Based on the IIA, we understand that Data Act will help meet these objectives by putting measures in place to ensure more public and private actors can benefit from the use of data, including through fair allocation of economic value among actors of the data economy. If done well, the Data Act could improve trust in data sharing and strengthen the use of data-driven insights for public good and social impact. In order to achieve these very worthy goals, we recommend addressing a few key elements within the future rules, including: 1. Allowing time for innovation 2. Addressing fairness in data sharing 3. Recognizing the value of data insights to advance social good 4. Considering issues associated with mandatory data sharing 5. Exploring alternative tools to improve access to data and fairness in data sharing We look forward to continuing to partner with the European Commission to shape the upcoming Data Act and create an innovative data-sharing ecosystem fully aligned with European values and fundamental rights.
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Meeting with Mairead McGuinness (Commissioner) and

11 May 2021 · Payments

Meeting with Filomena Chirico (Cabinet of Commissioner Thierry Breton)

10 May 2021 · Company policy for the Control of illicit pornography online

Meeting with Werner Stengg (Cabinet of Executive Vice-President Margrethe Vestager)

5 May 2021 · Artificial Intellligence

Meeting with Thierry Breton (Commissioner) and

22 Apr 2021 · Toward a new governance framework for the data economy

Response to Instant Payments

6 Apr 2021

Mastercard welcomes the opportunity to feedback on the Commission’s initiative on instant payments. Electronic payments are the foundation of the digital economy in Europe. We see the importance of giving consumers and businesses access to the full range of electronic payment types including cards, instant payments and hybrid services as well as non-digital payments - such as cash. Differentiation in payments enables consumers to choose a mechanism based on convenience, cost, protection or value proposition. It supports competition. There is a risk that regulatory intervention in payments to drive uniform business and cost models would leave consumers with fewer alternatives. It might also generate extra costs for consumers and merchants, particularly if new or additional functionality is mandated. Digital payments will be integral to the post-pandemic economic recovery; the Commission should encourage industry to continue investing in payments by maintaining a stable regulatory environment. We believe that consumer choice in payments is essential (whilst maintaining the highest level of safety and security). Consumers should be able to make an informed choice and have confidence in their chosen payment instrument. A variety of payment options are welcome in a competitive marketplace. The market is proving effective in driving new payment initiatives, services and schemes - delivering better services and choice for end users. European consumers also benefit from access to international payment schemes, enabling them to transact worldwide. Merchants should be able to select their preferred payment solution. Instant payments are a solution for many merchants; this functionality already exists in a number of markets and may offer attractive features in terms of cost, speed and certainty of payment. Cards are an attractive solution for many merchants because they optimize user experience (e.g. contactless), guarantee payment, offer fraud protection and have low processing costs. The cost to merchants of adding new payment mechanisms (at physical point of sale) can be onerous. Constant evolution of new mechanisms is often unaffordable for small merchants. The Commission should consider the cost impact of regulation before action is taken. Adding a different user experience, eg. based on QR-Codes, may also pose challenges. There is a need to maintain payer-payee dialogue at point of interaction to ensure transparency and efficiency. The EU is a highly competitive market that delivers efficient, secure and convenient payment solutions that meet consumer needs. Recent regulation (eg. PSD2 and PAD) has helped to encourage competition and bring new entrants to market. The Commission should continue to focus on setting a framework within which commercial activity and competition takes place. It should also continue to foster a regulatory level playing field to deliver the best results for the end user. The Commission‘s commitment to a proportionate approach to furthering instant payments is welcome. But it would be useful for all parties if the Commission gave a precise definition of what it means by instant payments, given the variety of schemes and services in this space. Mastercard believes that the market is proving effective in driving new payment initiatives, services and schemes. As such, we recommend that the Commission pursues the baseline option as the most effective means of enabling the market to continue innovating to meet consumer needs. This option includes monitoring and assessment of voluntary efforts. If required, the Commission could keep the non-legislative option in reserve, in case it identifies any shortfalls in market-based provision. We would welcome the opportunity to partner with the Commission on the design of minimum standards, particularly in relation to tackling fraud and protecting consumers. We believe that benefits can be achieved without the need for legislative or regulatory intervention.
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Meeting with Axel Voss (Member of the European Parliament) and Meta Platforms Ireland Limited and its various subsidiaries

25 Mar 2021 · Artificial Intelligence

Meeting with Agnieszka Drzewoska (Cabinet of Commissioner Mairead Mcguinness), Florian Denis (Cabinet of Commissioner Mairead Mcguinness)

24 Mar 2021 · Retail payments strategy, open strategic autonomy

Meeting with Miapetra Kumpula-Natri (Member of the European Parliament, Shadow rapporteur)

22 Mar 2021 · DGA

Response to Legislative framework for the governance of common European data spaces

5 Feb 2021

Mastercard welcomes the opportunity to provide feedback to the European Commission on its proposed Data Governance Act (“DGA”) as part of the public consultation on Data sharing in the EU – common European data spaces (new rules). Mastercard is supportive of the development of a human-centric data ecosystem which will empower individuals to have meaningful control over their data and encourage public entities and business to share and use data in a fair and transparent way. This is fully in line with our Data Responsibility Imperative that guides all our data practices across the organization globally. We agree that a harmonized framework if done well could improve trust in data sharing and strengthen the use of data-driven insights for public good and social impact. But if done poorly, it could disincentivize data sharing. We have identified five key areas, with supporting rationale, where we believe the current draft could be strengthened to improve trust in the EU’s data sharing ecosystem, whilst providing legal certainty. These include: 1. Putting in place a toolkit of options to ensure benefits to consumers, businesses and public entities. • The data sharing ecosystem is still in the early stages of development, therefore different forms of data sharing should be allowed and supported. • Non-data sharing options should be encouraged when they are better suited to achieving a particular aim. 2. Creating a level playing field for an innovative and sustainable data sharing ecosystem. • The creation of a sustainable data sharing ecosystem requires a principle-based framework. • Businesses need balanced regulation and the right incentives to create and maintain access to the data they hold. • Accountability is needed amongst all actors within the data sharing ecosystem. 3. Strengthening the use of data-driven insights for public good. • New data altruism organizations should not come at the expense of existing data collaborations. • Data collaborations between the private and public sector must adhere to strict ethical, security and privacy controls. • The EU should support the exchange of best practice for data for social good initiatives. 4. Clarifying roles and responsibilities within the data sharing ecosystem. • The criteria for qualifying as a data sharing services provider (data intermediary) should be clarified. • Clarity on purpose limitation is needed, whilst encouraging greater control by individuals, businesses and public entities over their data. • Enhanced transparency requirements are needed for public entities and data altruism organizations. 5. Providing guidance on how the DGA will interact with the GDPR and other EU law. • The new bodies proposed in the DGA create a multiplication of regulators that could confuse businesses and individuals and create legal uncertainty. • The DGA may have unintended consequences in respect of the current GDPR roles of processor and controller. • The DGA should promote a risk-based approach and not limit low-risk data uses that are beneficial for innovation. • The DGA should be aligned with the GDPR regarding data transfers. We look forward to continuing to partner with all stakeholders to enhance the current draft of the DGA and create an innovative data-sharing ecosystem fully aligned with European values and fundamental rights.
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Response to Directive/regulation establishing a European framework for markets in crypto assets

11 Jan 2021

Mastercard welcomes the opportunity provided by the Commission to give feedback on the proposal for a REGULATION OF THE EUROPEAN PARLIAMENT AND OF THE COUNCIL on Markets in Crypto-assets, and amending Directive (EU) 2019/1937. Please find our feedback in the attached document.
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Meeting with Pablo Fabregas Martinez (Cabinet of Commissioner Adina Vălean)

17 Dec 2020 · Meeting to share aviation experience.

Meeting with Werner Stengg (Cabinet of Executive Vice-President Margrethe Vestager)

27 Nov 2020 · AI White Paper

Response to Requirements for Artificial Intelligence

10 Sept 2020

Mastercard welcomes the opportunity to provide feedback to the European Commission’s Inception Impact Assessment (“IIA”) on an EU legislative initiative for AI. Mastercard wishes to express its support for Policy Option 4 as outlined in the IIA. We believe the Objectives highlighted by the IIA can be achieved in an appropriate and sufficient manner through a combination of Policy Options 1 (EU soft law (non-legislative) approach to facilitate industry-led intervention), 2 (EU legislative instrument setting up a voluntary labelling scheme) and 3b (EU legislative instrument establishing mandatory requirements for “high-risk” AI applications). As outlined in our response to the Commission’s Public Consultation on the AI White Paper, we believe that regulatory guidance and/or codes of conduct (for instance on AI auditability) in combination with a voluntary labelling system at EU level allowing AI actors to demonstrate their compliance with an AI normative framework for no-high risk AI applications may serve to establish consumer trust in the use of AI technologies in the EU. Whereas we support the idea in principle that the introduction of new compulsory requirements should be limited to high-risk applications, this is conditional on key aspects that are not yet clearly delineated, such as the test to determine if an application is “high-risk”, how and when an application will be assessed, and a clear definition of AI. We believe that the high-risk criteria outlined in the White Paper do not allow for the necessary flexibility for market actors and society to benefit from AI without producing onerous requirements. The qualification of certain specific sectors as high-risk does not consider the fact that sectors are constantly evolving and that AI applications may be used across sectors. The qualification of certain uses as “high-risk as such”, e.g. the use of AI for recruitment, is too rigid and ignores the potential benefits the AI application may bring as well as any available measures to mitigate risk. In relation to an enforcement mechanism to ensure effective compliance with any applicable requirements related to fundamental rights, we believe an appropriate enforcement approach combines an ex-ante self-assessment and an ex-post compliance assessment similar to what is established in GDPR. A self-risk assessment process should be based on the structure and content of a Data Protection Impact Assessment under GDPR (as the use of AI often requires a DPIA) but could include additional AI-specific sections related to bias, explainability and auditability. If a self-risk assessment indicates an AI application is likely to create high risk to fundamental rights, in light of severity and likelihood of potential harm, an organization should take steps to reduce the risk, for instance by implementing technical & organizational controls. If after the remediation steps have been taken, the high risk remains, companies should consult with the relevant competent authorities prior to deploying the AI application. This is similar to the consultation process in Article 36 GDPR. In relation to an enforcement mechanism for risks to safety, we believe that existing conformity assessment procedures in sectors where established structures already exist (automotive, healthcare, etc.) should be leveraged to address high safety risks engendered by AI applications in these sectors. Finally, any effective legislative initiative on AI requires a clear definition of the technology. In this respect, it should be considered that certain AI-like applications, e.g. regression analysis, have been around for years without engendering risks that cannot be addressed by the existing regulatory framework. For the purpose of delineating the scope of this legislative initiative, the definition should cover applications entailing additional risks that cannot be addressed by existing legislation, such as unsupervised machine learning.
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