Payment Services Directive PSD2 must be practicable for companies
The EU Commission is currently evaluating the second Payment Services Directive PSD2, which has been in force since 2016. In our statement, we emphasise that the intra-group exemption must be clarified in a future PSD2 amendment. Otherwise, groups with centralised cash management systems run the risk of having to apply for a licence as a payment service provider.
The explanatory memorandum to the current PSD2 also contains an exception. However, this is not interpreted uniformly by the supervisory authorities such as BaFin due to unclear wording, so that legal uncertainties arise. The EU Commission must refine this in a reform and formulate it more precisely.