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PSD2/PSD3 & regulatory advisory

PSD2 reshaped how payments are authorised, initiated and accessed across Europe — and PSD3, with the accompanying Payment Services Regulation, is proposed to extend and tighten that framework further.

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Overview

PSD2 brought strong customer authentication, open banking access under XS2A, and the rise of licensed TPPs. The PSD3 and PSR package builds on it, with proposals on fraud liability, spoofing and impersonation scams, data-access dashboards and a single licensing regime for payment and e-money institutions. Alongside it, the Instant Payments Regulation already requires euro-area PSPs to offer instant payments and Verification of Payee.

Run Ventures advises banks, PSPs, e-money institutions and technology vendors on what these regulatory changes mean in practice: which parts of the product, technology stack, customer journey and risk framework need to change, on what timeline, and with what supervisory engagement.

Our regulatory advisory work spans licence applications and passporting strategy, gap analysis against the proposed PSD3/PSR requirements, SCA and open banking API readiness, and ongoing compliance support as rules are finalised and transposed across member states.

From today's rules to a sequenced planCurrent PSD2 obligations are compared with the proposed PSD3/PSR requirements, and the gaps are turned into a sequenced plan.PSD2Gap analysisPlanCompliance

What we do

  • Licensing & passporting

    Licence applications and passporting strategy.

  • PSD3/PSR gap analysis

    Gap analysis against the proposed requirements, revisited as the text changes.

  • SCA & open banking APIs

    Strong customer authentication and open banking API readiness.

  • Instant payments & VoP

    Send and receive readiness and payee-verification journeys under the Instant Payments Regulation.

  • Ongoing compliance

    Support as rules are finalised and transposed across member states.

From PSD2 to PSD3/PSR

PSD2, in force today, brought strong customer authentication, open banking access under XS2A and the rise of licensed TPPs. The PSD3 and PSR proposals build on it, with attention on:

  • Fraud liability. Impersonation and spoofing scams, and who bears the loss.
  • Name checks. IBAN and payee verification.
  • Open banking. Data-access permissions and the standard of bank APIs.
  • Scope. A broader, more aligned regime for e-money and payment institutions.

We work out which parts of the product, technology stack, customer journey and risk framework would need to change, and with what supervisory engagement. See also our article on PSD3 and open banking.

Instant payments and payee checks

The Instant Payments Regulation already requires euro-area payment service providers to offer instant credit transfers and Verification of Payee, with later dates for non-euro member states. We help teams assess send and receive readiness, payee-check journeys, sanctions screening at instant speed and fraud controls that work in seconds. For the wider picture see the Instant Payments Regulation.

A sequenced plan

The result is a plan on a realistic timeline, rather than a static compliance checklist:

  • Licensing and passporting. Licence applications and a passporting strategy across member states.
  • PSD3/PSR gap analysis. Against the proposed requirements, revisited as the text changes.
  • SCA and open banking APIs. Strong customer authentication and open banking API readiness.
  • Ongoing compliance. Support as rules are finalised and transposed across member states.

Regulation feeds directly into strategy and card program design.

Preparing for PSD3/PSR?

Applying for a licence, preparing for PSD3/PSR or testing SCA and API readiness? Our consultants can walk through a sequenced plan for your business.

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