Consultation Response: Implementation of the revised EU Payment Services Directive (PSDII)

HM Treasury are seeking views on legislative changes proposed to meet the requirements of the revised Payments Services Directive II (2015/2366/EU) (PSDII).

The area that AIME is concentrating on is the “telecom exclusion” detailed in Article 3(l) of PSD, which assumes that a telecom provider, taking a payment for a third party service and adding that payment to the consumer telecoms bill is acting as a Payment Service Provider (PSP). PSP’s have to register and be authorised by the FCA. The exclusion from registration covers a limited range of products and services that can be purchased with a maximum value and a maximum monthly spend.

The other area of concern for AIME is that Networks Intermediaries, all the way to the merchant are potentially captured as “Payment Acquirers” requiring FCA registration.

AIMEs response to Treasury answered the questions being posed and covered in detail, the operational environment of telecoms based payments to ensure Treasury could brief ministers correctly if required.