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Existing PSP providers & PSD2 

The revised Payment Services Directive (PSD2) will take effect from 18 January 2018 and will be implemented into UK law via the Payment Services Regulations 2017 (PSRs). The main objective under PSD2 is to further develop the payments landscape within both the UK and across Europe.

PSD2 widens the scope of the PSD by covering new services and players as well as by extending the scope of existing services (payment instruments issued by payment service providers that do not manage the account of the payment service user), enabling their access to payment accounts.

Who is affected?

PSD2 is going to effect

  • businesses that are currently regulated payment service providers

  • businesses that operate under existing exclusions from the PSRs 2009

  • businesses that provide payment services that are coming within the scope of regulation for the first time – i.e. those providing account information services (AIS) or payment initiation services (PIS)

Additional requirements for current regulated payment service providers

Businesses that are authorised or registered under the Payment Services Regulations 2009 (PSRs 2009) will need to apply to be re-authorised or re-registered under the PSRs 2017 in order to continue providing payment services.

See below table showing key dates to look out for and summary of what needs to be provided to FCA to be able to continue to operate as a regulated PSP.

additional requirements under PSD2

As you can see from the above that most existing businesses holding PSP licenses needs to re-register or re-authorise between a relatively short window from 13 October 2017 to 13 April 2018. This would require affected PSPs to observe their existing procedures covering the above additional requirements, make changes where necessary to bring them in line with PSD2 standards or in certain cases document them from scratch, obtain approvals from senior management team and submit to the FCA before 13 April 2018. 

Next steps

Businesses that need re-registration and re-authorisation under PSD2 should take into account the significant amount of work it is required from them in terms of new documentation, confirmation on the current status of policies and procedures submitted at the time of previous application and completing the form itself. Failure to get re-registration or re-authorisation would stop them from operating as a PSP beyond 13 July 2018.

Zeeniya Consulting's experienced licensing and compliance team can discuss what requirements apply to your business, help you to identify what changes you will need to make and guide you through the process. Please do not hesitate to contact us for a free consultation and assessment.

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