VIVAWALLET GROUP OF COMPANIES
VIVAWALLET
The VIVAWALLET group of companies includes VIVABANK SINGLE MEMBER BANKING S.A.
ID: 389667750527-69
Lobbying Activity
Response to Digital services for simplifying business operations and reducing administrative costs – the business wallet
10 Jun 2025
DIGITAL BUSINESS WALLET We strongly and unequivocally support the European Commission initiative to expand the scope of application of the EUDIW towards its business-equivalent European Business Wallet including B2B, B2G and G2G applications. The European Business Wallet will be a critical milestone for the true harmonization of the Single Market, especially when it comes to the provision of financial services. More specifically, as a PSP we have been providing cross border payment services across EEA in 23 EEA countries since 2018 Either through branches or freedom of services passport, thus we have a very deep understanding of the significantly divergent national identification requirements (both as a supervised entity and as an AML obliged entity for our customers). Such divergent national requirements oftentimes have the same result as a barrier to enter cross-border markets, thus essentially undermining the European Single Market for (Financial) Services. A. BARRIERS FOR FINANCIAL INSTITUTIONS AS SUPERVISED ENTITIES BARRIERS FOR ALL CROSS-BORDER BUSINESSES BEFORE NATIONAL AUTHORITIES We have highlighted the administrative and supervisory barriers we have faced, throughout our cross EEA operations, on many occasions, including multiple Commission Consultations. For example, in the context of the Commission Targeted consultation on the review of the revised payment services Directive (PSD2) (July 2022), we underlined in our submission that European legislation, such as PSD2, unintentionally created national barriers for PSPs that derived from national implementing supervisory, reporting and enforcement requirements and practices. A typical example here would be the diverging national requirements for reporting obligations (supervisory, statistical, accounting/financial, etc. reporting): Not only does each country require varying reporting datasets, reporting frequency and templates, but importantly each country and each national authority in the same country, may require reporting entities to get access to different reporting online portals, with different technical specifications, different requirements to access the portal and, oftentimes, a time-consuming process for the reporting entity to identify themselves before each authority. Such identification process before the authority might also entail providing corporate documents officially translated in the local language as English translations might not be accepted! Importantly, for the access to online reporting portals and the submission of each report, each national supervisory authority required the issuance of eIDAS certificates from local QTSP and did not recognize QESs issued by another member state QTSP! In other words, national supervisory authorities themselves would essentially breach the eIDAS regulation. We, in order to meet our cross EEA reporting obligations, issued approx. 23 different certificates issued by national QTSPs! Thus, for a truly harmonized European Market it is critical to harmonize identification requirements before national authorities, thus, critically reducing the cost and time for doing business across the Union. This is critical for all businesses and not only for supervised institutions, as most businesses will have to interact with and identify themselves before a local authority at least once during their cross-border operations. Especially for SMEs the costs borne to produce locally accepted identification means can be significant and a deterrent factor for cross border expansion. II. AML KYC/KYB FRAGMENTATION FOR BUSINESSES It is evident that the new AML package will significantly facilitate the harmonization of fragmented KYC/KYB requirements at national level. Furthermore, the EUDIW is expected to facilitate the verification of identity (KYC) for natural persons. (continued in the attachment)
Read full responseMeeting with Maria Luís Albuquerque (Commissioner) and
22 May 2025 · Exchange with representatives of the innovation sector on financing opportunities and challenges.