Insurance Europe has published its comments on the review of the revised payment services framework (PSD2).
Insurance Europe welcomes the stated intentions of the European Commission to carry out a comprehensive review of the application and impact of PSD2, including an overall assessment of whether it is still fit for purpose and what challenges have arisen in its application.
It is important to ensure that lessons are learned and that policymakers quantify and qualify the increased costs of such a framework compared to the actual benefits and risks faced by the financial sector. An in-depth analysis is required to determine whether the PSD2 framework has successfully achieved its objectives: for example, improved services for consumers and increased competition in the market.
This is particularly important given the Commission’s on-going considerations regarding a possible open finance framework. It is crucial that any new initiative regarding data sharing is not based on a copy paste from the PSD2 framework. This is because, while PSD2 was designed to increase innovation and competition in banking and payment services, other sectors, such as insurance, have very different business models.
The review should also reflect on how to ensure a fair allocation of costs related to developing any new, cross-sectoral data-sharing infrastructure among different players to ensure a balanced approach to the funding and development of any new infrastructure.