In Access to Central Bank accounts, Non-Bank PSP, Payments, Safeguarding

📢 Industry Update: The European Payment Institutions Federation (EPIF) which represents non-bank Payment Services Providers (PSPs) released last week its position paper which, among others, reflects on the ECB’s Decision regarding non-bank PSPs’ access to central bank accounts – a topic we recently covered.

💡 Key Takeaways from EPIF’s Position:
– EPIF is disappointed with ECB guidance limiting central bank account use to payment settlement only.
– EPIF considers that ECB guidance contradicts the objectives of the Instant Payment Regulation (IPR) aimed at promoting instant transfers.
– EPIF considers that non-bank PSPs need access to central bank accounts for both settlement and safeguarding to operate effectively. ​

🔍 Why This Matters:
The ECB’s Decision dated 27 January 2025 is reshaping the European payments landscape, allowing non-bank PSPs to settle transactions directly in central bank money, reducing reliance on traditional banks. However, as EPIF points out and as explained in the ECB’s Decision, this access to central bank accounts is restricted for settlement purposes only and not for safeguarding purposes. As PSD3 is taking its final shape, this discussion is of critical importance to non-bank PSPs in the EU.

📩 What’s Next?
If your business is navigating this evolving regulatory space, now is the time to assess compliance requirements and strategic opportunities. At Dalir Law Firm, we specialise in payments law and can help your firm stay ahead of regulatory changes.

📖 Read EPIF’s full position paper here