The revised Payment Services Directive (PSD2) is required to be implemented in the UK by 13 January 2018. The Treasury has transposed PSD2 into UK legislation in the Payment Services Regulations 2017 (PSRs 2017). The FCA will continue as the competent authority responsible for authorising and supervising payment service providers under PSD2. The Payment Systems Regulator will also be responsible for certain aspects which relate to payment systems.
What will happen?
Certain firms will need to become registered or authorised for the first time as a result of PSD2. Existing payment institutions and e-money institutions will need to be re-registered or re-authorised. The FCA will open for applications on 13 October 2017.
Authorised payment institutions (API)
APIs will need to provide the information to the FCA before 13 April 2018. Existing authorisations will cease to have effect on 13 July 2018 and firms that have not been re-authorised may be committing a criminal offence if they continue to provide regulated services after this date.
Small payment institutions (SPI)
SPIs will need to provide the information to the FCA before 13 October 2018. Existing registrations will cease to have effect on 13 January 2019 and firms that have not been re-registered may be committing a criminal offence if they continue to provide regulated services after this date.
Account Information Services (AIS) and Payment Initiation Services (PIS)
AIS and PIS are payment services under PSD2. Therefore, firms that wish to provide these services will need appropriate authorisation or registration.
Firms that are not already a payment service provider or exempt, that want to provide PIS (whether alone or with other payment services) will need to apply to be authorised as an API. Firms that only want to provide AIS may apply instead to be registered as a registered account information services provider (RAISP).
More services will be brought within the FCA’s scope by PSD2. These include account aggregation services which aim to help consumers manage their finances by bringing all of their bank account data together in one place, and services that allow consumers to make payments in different ways online, without using a credit or debit card.
PSD2 also introduces a number of new requirements around how firms treat their customers and handle their complaints, and the data they must report to the FCA.
How will Thistle help you?
We are able to assist you in all areas of your PSD2 application and will work with you to review or create the required documentation and submit a completed application. If you would like further information on how Thistle can help you, please contact us on 020 7436 0630 or email us on firstname.lastname@example.org.