PSD3 Compliance Process Report
1. Summary of PSD3 Scope and Key Changes
Payment Services Directive 3 (PSD3) is a forthcoming EU legislative update aimed at modernizing the regulatory framework for payment services. It builds upon the existing PSD2 (Directive (EU) 2015/2366) and is designed to bring the payments sector into the digital age while keeping security, competition, and consumer protection at the forefront. In June 2023, the European Commission proposed PSD3 alongside a complementary Payment Services Regulation (PSR) as part of a broader “financial data and payments” package. Together, PSD3 (a directive) and the PSR (an EU regulation) seek to enhance the safety and efficiency of electronic payments, strengthen consumer rights, foster innovation, and ensure a consistent regulatory approach across all EU member states. PSD3 will focus on areas such as licensing and supervision of payment institutions and electronic money institutions, while the PSR will contain uniform rules for providing payment services that apply directly in all member states.
The main objectives and changes introduced by PSD3 can be summarized as follows:
Combatting Fraud and Enhancing Security: PSD3 intensifies measures to prevent payment fraud by building on the strong customer authentication (SCA) requirements of PSD2 and addressing new fraud patterns that have emerged. Notably, it targets social engineering and impersonation fraud, where criminals trick customers into authorizing payments. To counter these, PSD3 will strengthen SCA rules and enable payment service providers (PSPs) to share fraud-related information among themselves. Consumers who fall victim to fraud will have expanded refund rights, further encouraging PSPs to proactively combat scams. For example, PSD3 is expected to make PSPs liable for certain authorized push payment fraud scenarios (such as when a customer is duped by someone posing as bank staff), and require telecom operators to cooperate with banks in preventing phone-based fraud. Overall, the goal is to adapt the security framework to emerging threats that were beyond PSD2’s original scope (e.g., fraud via manipulation despite SCA).
Improving Consumer Rights and Transparency: PSD3 bolsters consumer protections and information transparency in payment services. For instance, it mandates clearer and more detailed information on account statements and receipts, including transparent disclosure of any ATM withdrawal fees. Consumers will also gain greater control over their data and consents: they must be able to easily see and manage which third-party providers have access to their financial data and for what purpose. This will be facilitated by requiring banks to provide permission dashboards for customers, enhancing trust in data sharing. Additionally, PSD3 ensures consumers can continue to make electronic payments safely and conveniently across the EU (domestically and cross-border, in euro or other currencies) without hidden charges or unwarranted delays. These enhancements safeguard consumer interests and address complaints related to insufficient transparency under PSD2.
Level Playing Field between Banks and Non-Banks: A key aim of PSD3 is to eliminate disparities between traditional banks and non-bank payment providers (fintechs, e-money institutions, etc.), thus fostering fair competition. To achieve this, PSD3 will allow duly regulated non-bank payment institutions direct access to all EU payment systems (e.g., SEPA clearing systems) that were historically accessible only to banks. This change means fintech companies will no longer need a sponsoring bank to participate in schemes like SEPA, provided they meet the necessary safeguards. Additionally, PSD3 merges the Electronic Money Directive (EMD2) into the payment services framework, effectively integrating electronic money institutions (EMIs) as a subtype of payment institutions and repealing EMD2. By consolidating licensing and prudential requirements for banks, payment institutions, and EMIs, PSD3 aims to ensure consistent rules and supervision across all providers. Non-bank PSPs will face updated authorization and capital requirements (e.g., adjusted initial capital reflecting inflation) in exchange for greater opportunities to compete on equal footing with banks.
Strengthening Open Banking and Data Sharing: PSD2 introduced the concept of open banking, allowing third-party providers (TPPs) to access bank account data (with customer consent) for account information and payment initiation services. PSD3 seeks to improve the functioning of open banking interfaces and remove remaining obstacles that have hindered TPPs. Under PSD2, many banks’ dedicated APIs varied in quality, uptime, and speed, causing frustration among fintechs. PSD3/PSR directly addresses this by setting clear technical performance standards for APIs, such as minimum uptime (e.g., aiming for >99% availability) and prompt response times for API . Banks will be expected to upgrade their APIs to meet these standards, ensuring reliable and high-speed data exchange. Importantly, PSD3 plans to eliminate the need for “fallback” interfaces (screen-scraping or alternative access) by making primary APIs robust and mandatory. Alongside technical enhancements, PSD3 improves consumer control: it will enforce granular consent management so that customers can authorize, view, and revoke TPP access easily. Moreover, in conjunction with PSD3, the Commission has proposed a Financial Data Access Regulation (also known as open finance, FIDAR) to extend secure data-sharing principles beyond payments to other financial sectors. This open finance framework will build on PSD3 by establishing standardized data access rights and interfaces for products like mortgages, loans, investments, etc., marking the next step towards a wider data-sharing ecosystem.
Cash Access and ATM Services: Recognizing the continued importance of cash, PSD3 introduces measures to improve access to cash via retailers and ATMs. Currently, EU retailers can offer “cash-back” (cash withdrawal at point of sale) only linked to a purchase. PSD3 will allow retailers to provide cash withdrawal services up to a certain small amount (e.g., €50) without requiring a purchase, and crucially, without needing a PSP license or agent status. This change, however, comes with conditions: retailers must clearly inform customers of any fees associated with the service. Similarly, PSD3 clarifies rules for independent ATM deployers (operators of ATMs not owned by banks), allowing them to offer cash services without a bank/PI license under specified conditions. Both measures aim to ensure consumers – especially in rural or underserved areas – maintain convenient access to cash, while increasing transparency around fees. The proposal underscores that although digital payments are growing, maintaining cash availability is part of inclusive financial services.
Harmonization and Stronger Enforcement: Under PSD2 (a directive), member states transposed rules differently, and national regulators’ approaches to supervision and penalties have varied. PSD3 tackles this by shifting many detailed rules into a directly applicable regulation (the PSR), thereby reducing divergent national interpretations. It also calls for more consistent supervisory practices and cooperation across the EU. For example, the PSR will harmonize penalties for non-compliance and enforcement actions, ensuring that PSPs face similar consequences for violations regardless of jurisdiction. PSD3 outlines clearer and possibly expanded powers for regulators to supervise payment institutions, including common guidelines on license authorizations, ongoing supervision, and even withdrawal of authorizations in serious cases. By updating authorization and supervision frameworks for non-bank PSPs, the new rules aim to ensure a level playing field and uniform consumer protection across the EU. In practical terms, a payment institution operating in multiple EU countries should experience more consistent regulatory treatment and expectations. The strengthened harmonization also means that PSPs can more easily scale their services across borders without navigating significantly different national requirements.
In summary, PSD3 (with the PSR) is an evolutionary step that refines and reinforces the PSD2 framework rather than revolutionizing it, as noted by EU officials. The initiative addresses the shortcomings identified in PSD2’s implementation: improving security against new fraud threats, closing gaps in open banking, equalizing conditions for non-banks, ensuring cash remains accessible, and unifying rules enforcement. By doing so, it aims to create a more secure, competitive, and consumer-friendly payments environment in Europe. Stakeholders from banks and fintechs to merchants and consumers will all feel its impact:
Banks and traditional financial institutions will need to modernize legacy systems for enhanced data sharing and meet higher security standards, even as they face increased competition from new entrants
Fintechs and third-party providers will gain more opportunities (like direct system access), but with those come stricter regulatory obligations and oversight.
Consumers should benefit from improved protection (e.g., stronger fraud refunds), greater transparency (clearer fees and account info), and continued trust in a secure payments market.
Ultimately, PSD3’s success will be measured by a thriving European payments ecosystem that balances innovation with safety and user rights.
2. Steps for Current State Analysis in Preparation for Compliance
To ensure compliance with PSD3, financial institutions, fintech companies, and payment service providers should start with a thorough current state analysis. This process evaluates the organization’s existing systems, policies, and controls against the new PSD3 requirements to identify gaps. Key steps for conducting an effective current state and gap analysis include:
Understand the PSD3 Requirements and Differences: First, the organization should comprehensively review the PSD3 proposal (and related PSR) to map out all new or changed obligations compared to PSD2. This involves studying official texts, regulatory technical standards (RTS) drafts, and authoritative commentary to pinpoint what exactly will change. Key areas to focus on include customer authentication rules, data interface/API standards, consumer rights (disclosures, complaints), prudential requirements (capital, safeguarding), and any new reporting or audit obligations. By compiling a detailed checklist of PSD3 requirements (especially those that differ or are new relative to PSD2), the institution creates a baseline for the gap analysis. For example, note if PSD3 requires a wind-down plan for PIs (which PSD2 did not explicitly) or if it extends SCA to new scenarios. This regulatory analysis ensures no aspect of the new directive is overlooked.
Inventory Current Processes, Systems, and Controls: Next, perform an internal assessment to document the status quo in all relevant areas:
Technology and Infrastructure: Catalog the current payment processing systems, authentication platforms, customer channels (web, mobile), and open banking APIs. Evaluate these against PSD3’s expected technical standards. For instance, list the performance of your APIs (uptime, average response time) and compare with PSD3’s likely targets (e.g., 99%+ availability, sub-5 second response standards). Also assess if the tech stack (databases, encryption, etc.) meets the anticipated security requirements (such as support for TLS 1.3, OAuth2.0, or the capacity to handle increased data sharing).
Security and Data Protection Measures: Examine existing data security policies, encryption methods, and access controls. Are customer data and payment credentials stored and masked in compliance with GDPR and expected PSD3 enhancements?. Check if you have measures like multi-factor admin access, data loss prevention, and regular security testing in place. If PSD3 will mandate stronger fraud data sharing or require participation in anti-fraud information exchanges, note whether your current security setup can integrate with such systems.
Customer Authentication Processes: Document your current SCA implementation: how do customers log in and authorize transactions today (passwords, SMS OTPs, biometric app authentication, etc.)? Are you leveraging any PSD2 exemptions (like transaction risk analysis for low-value payments) and how effective are they? Identify gaps relative to PSD3’s SCA updates – for example, if PSD3 prolongs AISP data access without re-authenticating every 90 days, can your systems handle that (i.e., maintain tokens longer)? If PSD3 demands biometric options or alternatives for those without smartphones, list what you currently offer and where upgrades might be needed.
Processes and Policies: Review all relevant internal policies (incident response, third-party risk management, complaint handling, etc.) and process flows. Are they documented and in line with PSD2? Many PSD3 changes (e.g., improved transparency in statements, faster dispute resolution timelines) will require process adjustments. For example, if PSD3 introduces a stricter timeline to refund fraud victims, check your refund process timing and identify if it needs speeding up. Also, check governance structures: do you have clear compliance ownership and reporting lines, an independent risk and audit function, etc., as PSD3 will emphasize effective internal governance and controls.
Records and Documentation: Ensure you have a full inventory of documentation that regulators might expect. Under PSD3, payment institutions will likely need to prepare new documents such as a detailed wind-down plan, enhanced business continuity plans aligned with DORA (Digital Operational Resilience Act), and possibly updated security policies reflecting data-sharing arrangements. List which of these you already have, which need updates, and which are missing.
Identify Compliance Gaps: With the above two analyses, create a gap matrix comparing each PSD3 requirement to your current status. Mark each item as “Compliant/Already in place,” “Partially Compliant,” or “Not Compliant.” For each gap, assess its materiality (how critical is it to fix) and complexity (effort required to address). Common gaps might include: insufficient API performance (e.g., current API uptime is 95% vs required 99.5%), missing consent management tools for data sharing, no existing process for new consumer rights (such as explicit ATM fee disclosures), or inadequate documentation (like no wind-down plan). Prioritize gaps that pose regulatory breach risks or consumer harm – for instance, failing to implement required SCA changes or not segregating customer funds properly would be high-priority gaps.
Develop Remediation Strategy and Action Plan: For each identified gap, devise a clear remediation action. This might include technology changes, process re-engineering, policy updates, or staff training. For example, if API throughput is a gap, the action could be to upgrade server capacity and optimize code, or adopt a managed API gateway that meets performance needs. If a gap is procedural (say, no process for data breach notification within 24 hours as might be required by DORA/PSD3), define the steps to create one, assign an owner, and set a deadline. It’s advisable to create a compliance roadmap document listing all initiatives, owners, required resources. Be sure to include dependencies (e.g., “New SCA software must be deployed before mobile app update;” or “Legal must approve updated terms before publishing”). Also, include contingency planning: identify areas where you might need external support (consultants or vendors) to meet the requirements on time.
Secure Management Buy-In and Resources: Present the findings of the gap analysis and the proposed action plan to senior management and the board. Ensuring leadership understands the scope and urgency of PSD3 compliance is key to obtaining necessary budget and staffing. Provide a high-level summary of risks of non-compliance (regulatory fines, customer attrition, operational disruptions) versus the benefits of early compliance (avoiding penalties, gaining customer trust, competitive advantage in open banking). Once approved, allocate budget for technology upgrades, potential new hires or training, and possibly external advisory servicesdotfile.com. Establish governance for the remediation program – e.g., a PSD3 compliance taskforce or steering committee that will monitor progress.
Implement Interim Monitoring: As remediation projects kick off, introduce a mechanism to track progress. Regular status meetings or dashboards should report on key compliance KPIs (e.g., % of systems updated, % of staff trained, number of outstanding high-risk gaps). This ensures timely issue escalation and keeps the organization on track to meet regulatory . Internal audit or an appointed project management office can oversee this tracking, providing independent assurance that the gap-closing actions are effective and on schedule.
Performing the above current state analysis and gap assessment early gives organizations a significant advantage. It clarifies where resources should be focused and prevents last-minute fire drills. Essentially, it creates a “to-do list” derived from regulatory requirements, tailored to your unique situation. Financial institutions that thoroughly understand their starting point can chart a realistic path to full PSD3 compliance and are less likely to encounter surprises during regulatory examinations or at the go-live date.
3. Common Gaps and Strategies to Address Them
Drawing on experiences from PSD2 compliance and regulator feedback, several common deficiencies have been observed among payment service providers. Anticipating and addressing these in the PSD3 transition will be crucial. Below are frequent compliance gaps and suggested strategies to remedy them:
Inconsistent or Underperforming Open Banking APIs: Under PSD2, many banks provided dedicated APIs for third-party access, but quality and reliability varied greatly. Common issues included frequent downtime, slow response times, and incomplete functionalities, which frustrated third-party providers and sometimes forced them to revert to screen scraping (the “fallback”). If these issues persist, they constitute a compliance gap under PSD3’s stricter standards. Strategy: Invest in and upgrade your API infrastructure. Implement robust API management solutions that include throttling, load balancing, and 24/7 monitoring. Aim to meet or exceed the expected performance benchmarks (for instance, redesign critical API calls to reduce latency and ensure >99% uptime through redundancy). Additionally, adhere to industry standards like the Berlin Group API specifications or Open Banking UK standards, which can simplify compliance by design. Implement automated testing and monitoring to continuously measure API availability and response times, and publish these metrics if required to demonstrate transparency. Removing obstacles, as PSD3 demands, might also include streamlining onboarding for TPPs (e.g., a quick and standardized registration and certification process) and eliminating any unnecessary restrictions that PSD2 APIs had (like requiring redundant consent steps). Ultimately, better APIs not only meet compliance but also improve your ecosystem connectivity, benefiting your business.
Suboptimal Strong Customer Authentication (SCA) Implementation: Many institutions struggled with SCA rollout under PSD2 – either doing the bare minimum or misapplying exemptions. For example, some PSPs overused “trusted beneficiary” or low-value exemptions, potentially exposing themselves to fraud, while others applied SCA in clunky ways that harmed user experience. PSD3 clarifies and expands SCA rules, so gaps may arise if current SCA setups aren’t aligned. Strategy: Revisit your entire authentication journey in light of PSD3. Ensure multi-factor authentication is applied wherever required, but also simplify the process for users through intelligent design (e.g., use biometric authentication within mobile apps for a smoother experience). Address known weak points: if your SCA heavily relies on SMS OTP (which can be vulnerable), consider adding more secure options like app-based or token-based authentication. Pay particular attention to new SCA exemptions and conditions PSD3 introduces. For instance, PSD3 will clarify the treatment of merchant-initiated transactions (MIT) and other special cases – update your systems to handle these correctly (perhaps tagging recurring MIT payments differently to bypass SCA, yet still monitoring them for fraud). Also, ensure compliance with PSD3’s requirement that SCA methods are inclusive and not dependent on a single device or technology. That means providing alternative methods for customers who don’t have smartphones or who have disabilities – a gap if currently you rely only on smartphone push notifications, for example. The fix could be offering hardware OTP tokens, voice phone-based OTP, or biometrics via other channels. Regularly test your SCA flows from a user perspective and measure drop-off rates; a well-implemented SCA under PSD3 should be both secure and user-friendly. Keep records of your fraud rates and SCA exemption usage, as regulators may review whether your application of SCA is justified and optimized.
Inadequate Fraud Monitoring and Incident Response: While PSD2’s SCA helped reduce unauthorized fraud for online payments, social engineering fraud and scams (like Authorised Push Payment fraud) have surged, often exploiting human factors rather than technical loopholes. Institutions that haven’t upgraded their fraud monitoring systems to detect these newer fraud typologies may find themselves non-compliant with PSD3’s expectations to curb fraud. Also, PSD2 required reporting major incidents to regulators, and some PSPs have been slow or incomplete in doing so. Strategy: Enhance your fraud detection and response framework. Deploy advanced tools (machine learning models, behavioral analytics) that analyze transaction patterns, user behavior, device fingerprints, etc., in real time to flag unusual transactions for additional . For example, implement controls to detect if a customer’s payment behavior suddenly deviates (possibly indicating they’re being manipulated) – such transactions could be paused for manual review or a confirmation call. PSD3 explicitly allows PSPs to share fraud-related information among themselves, so consider joining or establishing industry consortia or fraud data exchanges to stay ahead of emerging scams. If a customer falls victim to impersonation fraud, PSD3 will likely hold PSPs responsible for refunds unless they have evidence of gross negligence. This shifts the approach from “blame the user” to “protect the user,” meaning your internal policies should err on the side of assisting the customer quickly and then investigating the fraud MO to prevent recurrence. Additionally, strengthen your incident reporting processes. Create clear internal guidelines for what constitutes a major incident (security breaches, service outages, fraud spikes) and how to escalate and report to regulators within required time frames. Regularly run simulations (e.g., a mock data breach drill) to test if your team can detect, contain, and report incidents swiftly. This preparation will help avoid compliance breaches and reduce damage when a real incident occurs.
Client Fund Safeguarding and Prudential Shortcomings: Some payment and e-money institutions have historically struggled with fund safeguarding obligations – e.g., not segregating customer funds properly, or delays in depositing funds in safeguarded accounts – as evidenced by regulatory findings. PSD3 will continue to emphasize robust safeguarding (especially as EMI rules merge into it) and may introduce tighter rules (like specific audit requirements for safeguarding, which regulators like the Central Bank of Ireland already enforce). Another potential gap is around capital adequacy and wind-down planning; smaller fintechs might not have updated their capital needs or formulated contingency plans as PSD2 didn’t explicitly require wind-down plans. Strategy: Conduct a thorough review of your safeguarding arrangements. Ensure all customer funds (prepaid balances, payment float, etc.) are isolated from your own operational accounts according to the rules – typically end-of-day segregation at minimum, but immediate segregation is best practice. Regularly reconcile these accounts and keep records to prove that total safeguarded funds match customer liabilities. Engage an external auditor to annually audit your safeguarding compliance (many regulators already mandate this). Strengthen contracts with safeguarding institutions (banks or insurers providing guarantees) to ensure clarity of protections. In terms of prudential requirements, re-calcute your capital needs under PSD3’s new thresholds and be prepared to raise additional capital if needed. Develop a wind-down plan if you don’t have one: this plan should outline how you would manage an orderly cessation of services, return client funds, and maintain critical operations during a failure scenario. Not only is this likely a formal requirement under PSD3 for authorization, it’s also a valuable exercise in risk management. If internal resources are thin on these matters, bring in consulting or legal experts who have done such plans. By shoring up safeguarding and prudential compliance, you not only satisfy regulatory demands but also build trust with clients and partners.
Governance, Internal Control, and Documentation Gaps: A less tangible but crucial area is internal governance and compliance culture. Regulators have noted instances of inadequate internal controls – e.g., compliance and risk functions that are understaffed or not truly independent, or boards not sufficiently engaged in oversight. Some fintech startups treated PSD2 compliance as a one-time checklist rather than an ongoing process, leading to stale policies and outdated procedures. PSD3 raises the bar on internal governance (for example, requiring stronger internal audit involvement and possibly fit-and-proper requirements for key staff). Strategy: Strengthen your “three lines of defense.” Ensure that your compliance/risk management function (second line) and internal audit (third line) are empowered, resourced, and independent. For instance, internal audit should not be auditing areas they helped implement – maintain operational independence, which might involve using external auditors if needed. Conduct an organizational gap analysis: do you have committees or designated roles for key compliance areas (e.g., a Data Protection Officer for GDPR, a security officer for ICT risk, etc.)? If not, assign those roles and clarify responsibilities. Provide training to your board and senior management on PSD3 implications so they can fulfill oversight duties effectively. Additionally, update all policies and procedures to reflect PSD3 changes – from your customer terms and conditions to internal manuals on handling disputes or operational incidents. Often neglected are things like record-keeping: ensure you can document compliance (logs of API calls, authentication attempts, consents obtained, audit trails of transactions) because regulators will expect evidence, not just assertions. Finally, promote a culture of compliance and ethical behavior. Frontline staff should be encouraged to report issues, and management should prioritize compliance projects. Some firms appoint a “PSD3 Program Manager” or similar to coordinate all moving parts – a practice that can bring focus and accountability. Remember, strong governance and controls are not just about avoiding penalties; they help the business run more efficiently and resiliently. For example, a clear procedure on handling a customer’s open banking consent revocation (with roles and steps defined) reduces confusion and error when that scenario arises.
In all, proactively addressing these common gaps will smooth the path to PSD3 compliance. The overarching strategy is early identification and remediation – the sooner you find and fix a weakness, the lower the risk of non-compliance incidents or last-minute scrambles. Moreover, many of these enhancements (like better API performance, rigorous fraud defenses, or improved governance) have business benefits beyond compliance: they can lead to improved customer satisfaction, fewer fraud losses, and stronger reputation in the market. Forward-thinking institutions view compliance investments as dual-purpose: reducing regulatory risk while also sharpening their competitive edge and operational excellence.
4. Roles of External Audit, Internal Audit, and Consulting Services in the Compliance Process
Achieving and maintaining compliance with PSD3 will require coordinated efforts across various assurance and advisory functions. Internal audit, external audit, and consultants each play distinct yet complementary roles in supporting organizations through this transition:
Role of Internal Audit
Internal audit serves as the third line of defense, providing independent assurance within the organization that controls and processes are effective. In the context of PSD3 compliance:
Ongoing Assurance during Implementation: Internal audit should be involved throughout the PSD3 implementation project to conduct readiness reviews and control testing. This proactive involvement is recognized as a good practice; in fact, under PSD2’s RTS, firms were expected to have independent auditors (which could be internal, if sufficiently independent) evaluate the security measures and compliance with the technical standards on a periodic basis. Internal auditors can perform interim audits on key milestones – for example, after the development of new SCA processes, they could test whether these meet regulatory requirements (e.g., dynamic linking, correct exemption handling). By doing so, they provide management with early warning of any compliance shortcomings, reducing the risk of discovering issues at a late stage. Internal audit should ensure that the implementation of PSD3 requirements is well governed, documented, tested, and evaluated internally, per regulatory expectations.
Independently Auditing Compliance Measures: Certain PSD3 obligations will explicitly require audits. For example, under PSD2’s RTS Article 3, an operationally independent audit of security measures was required at least yearly, and an external audit every 3 years if transaction risk analysis exemptions were used. Under PSD3, internal audit can be the function conducting these audits as long as it was not involved in implementing the controls (to maintain objectivity). Internal audit should check areas like: the SCA implementation (does it satisfy all elements of the RTS?), the integrity of open banking interfaces (have all “obstacles” been removed?), and compliance with new consumer protection rules (e.g., are refund processes aligned with PSD3’s expanded rights?). If internal audit lacks specific expertise (say, in IT security), they should coordinate with external experts or co-sourced auditors to fulfill these requirements. The key is that an independent, expert review of PSD3 controls is performed and documented, either by internal audit or external parties.
Advisory and Monitoring Role: While maintaining independence, internal auditors often act as advisors in complex regulatory projects. They can help management interpret broad PSD3 obligations into control requirements and suggest improvements without compromising their ability to audit. For example, internal audit might advise on what a “robust” anti-fraud measure looks like or whether the documentation for safeguarding funds is audit-ready. They can also monitor remediation action plans (from the gap analysis) as part of their audit follow-ups, ensuring that issues identified are being resolved timely. If internal audit sees slippage in the compliance timeline or recurring issues, they will report these to the audit committee or board, prompting corrective action at a high level. Essentially, internal audit provides a confidence check at each phase: design, implementation, and post-implementation of PSD3 measures.
Preparing for Regulatory Inspections: Internal audit should evaluate whether the organization is prepared for a possible regulatory PSD3 compliance inspection or authorization review. This means checking that all required documentation (policies, reports, training records) is in order and that staff are aware of their responsibilities. Internal audit might conduct a “mock audit” simulating what questions regulators might ask. Areas like governance (board minutes reflecting PSD3 discussions), risk assessments, and previous compliance issues remediation should be examined. By doing so, internal audit helps avoid nasty surprises during official examinations and demonstrates to regulators that the institution takes self-audit seriously.
In summary, internal audit’s role is to be the institution’s eyes and ears on compliance integrity, both during the rush of implementation and as a steady-state function thereafter. Their involvement assures senior management and regulators that the internal control environment remains robust amid significant change.
Role of External Audit
External audit refers to independent third-party auditors who might be engaged for statutory financial audits or specific compliance audits. In PSD3 compliance:
Mandatory Independent Audits: PSD3, much like its predecessor, may mandate that certain reviews be carried out by qualified external auditors. Under PSD2’s SCA rules, for instance, any PSP using the transaction risk analysis exemption had to have an external auditor perform an audit of its model initially and every 3 years. We can expect similar or additional requirements under PSD3 (e.g., if new models or innovations are introduced, or for critical IT security audits). When such mandates exist, the organization must engage an external audit firm with the requisite IT and payments expertise to perform the audit and provide a report. External audits provide an unbiased verification that, say, the fraud rates reported are accurate and below required thresholds, or that the IT security framework meets the guidelines. Organizations should plan for these in their compliance budget and timeline, because scheduling external audits (and remediating any findings they identify) can be time-consuming.
Annual Financial Audit with Compliance Focus: While the primary job of the external financial auditor is to opine on financial statements, they are also attuned to compliance issues that could have material impacts (like fines or operational losses). Many regulators (e.g., in Ireland or the UK) now include safeguarding of customer funds checks as part of external audits of payment/e-money institutions. An external auditor might issue a comfort report on safeguarding compliance, verifying that client money is properly segregated and protected. This has effectively become a regulatory expectation in some jurisdictions. Under PSD3, external auditors will likely continue to evaluate things like loss provisioning for fraud reimbursements (given expanded refund obligations) or any going concern implications if a firm’s license conditions change. Management should thus engage external auditors proactively about PSD3 – for example, discuss how new revenue transparency requirements might affect revenue recognition or whether expanded customer rights necessitate contingent liabilities or provisions. External auditors might not be experts in the regulation per se, but they can alert you to any areas where non-compliance could distort the financial results or require disclosure.
Third-Party Attestation and Certification: Beyond mandatory audits, organizations might seek external attestations to demonstrate compliance to clients or partners. For instance, an API platform might get a third-party certification that it meets PSD3’s interface standards, or a fintech might have an external firm perform a “PSD3 readiness assessment.” These voluntary audits can be strategic. They provide an extra layer of assurance to your board and to regulators that an independent party has vetted your compliance. If you choose to do this, ensure the external auditor’s scope is well-defined – maybe using a control framework like ISAE 3000 or similar for assurance on compliance controls. They could cover, say, the end-to-end open banking process including TPP onboarding and API security. The output would be a report you can share with regulators during licensing or exams.
Outsourced Internal Audit Functions: In cases where internal audit is not sufficiently resourced or lacks specialized skills, external firms (often the big consulting/audit firms) can be engaged to co-source or outsource internal audit activities. This means an external team might perform audits on behalf of your internal audit function. This is common in smaller fintechs. It ensures an operationally independent audit takes place, and that expertise (e.g., ethical hacking skills for an IT security audit) is available. If you go this route, ensure the external auditors are truly independent (no conflict of interest, not the same team that might be providing consulting on PSD3 to you). Regulators will look at the credibility of any external audit reports you rely on, so choose reputable firms or certified auditors.
In essence, external audit brings an outside perspective and credibility. Their sign-off or findings can validate your compliance in the eyes of regulators and can highlight issues internal teams might miss due to familiarity or blind spots. Engaging with external auditors early about PSD3 will help align expectations and streamline the eventual audit process. Remember, once PSD3 is in force, regulators might ask for external audit results or even require firms to submit external compliance audit reports annually. Being prepared for this is part of a sound compliance strategy.
Role of Consulting and Advisory Services
Consultants and advisory firms can play a crucial role in navigating the complexities of PSD3. Their contributions often include:
Subject Matter Expertise and Best Practices: Top consulting firms and niche regulatory advisors track EU regulatory developments closely and often contribute to industry responses. They have a deep understanding of PSD3’s nuances and practical implications. For example, they’ll know how other banks in the market are approaching API improvements or what technology solutions have been successful for SCA. Engaging consultants can provide access to this expertise and cross-industry insights, which is especially valuable if your internal team has limited experience with large-scale regulatory projects. They can advise on what operating model changes PSD3 might entail, or help interpret ambiguous requirements by referencing regulatory intent and precedent.
Gap Analysis and Strategy Formation: While many organizations will do an internal gap analysis, consultants can offer an independent review or even lead the process for you. Given their experience, they might spot gaps that internal teams overlooked. They often use structured methodologies or checklists gleaned from multiple PSD2/PSD3 projects. After assessing your readiness, consultants can help prioritize remediation efforts—for instance, by scoring gaps by compliance risk and implementation difficulty, they can help you sequence projects for maximum efficiency. Moreover, they’ll tailor a roadmap aligning with regulatory milestones, often working backward from the effective date to create a detailed project plan with workstreams (IT, legal, operations, etc.). This plan can also include budgeting of costs and resources, something management will require for .
Project Management and Implementation Support: Compliance with PSD3 is essentially a large, multi-disciplinary project. Many consulting firms offer project management office (PMO) services or can augment your team with specialists. These consultants ensure that the numerous tasks (software updates, policy drafts, training sessions, etc.) are coordinated and stay on schedule. They bring frameworks for tracking progress, risk logs, and status reporting that keep everyone . If internal teams are stretched thin, consultants can take on heavy-lift items. For example, they could draft new policies or map data flows for consent management, taking those tasks off your staff’s plate. They can also liaise across departments (IT, legal, compliance, business units) to facilitate communication, which is sometimes easier for a neutral external party to do. In technical areas, consultants can provide very specific help – such as API developers familiar with open banking standards, cybersecurity experts to test new SCA mechanisms, or data privacy advisors to update consent language.
Training and Change Management: PSD3’s impact will be felt organization-wide, and ensuring everyone understands the changes is vital (from IT developers to customer service reps). Consultants can develop and deliver custom training programs for different . For instance, they might run a workshop for the IT team on PSD3 API security expectations, another for compliance/legal on changes in liability and disclosures, and a simpler briefing for front-line staff highlighting how customer interactions (like complaints or queries about rights) will change. They can also help create internal communication plans, FAQs, and playbooks so that once PSD3 goes live, employees know what’s expected. Effective change management, often guided by experienced consultants, ensures that the organization not only implements new processes on paper but actually adapts behavior and culture to the new regulatory environment.
Regulatory Liaison and Advocacy: Many consulting firms maintain dialogue with regulators and industry bodies. They can advise on how best to approach regulators if you need clarifications or waivers. For example, if certain PSD3 technical requirements pose implementation challenges, consultants might help you draft a request to the national authority for guidance or an extension, using language that resonates with regulatory concerns. Also, if during compliance testing you find an issue that might require self-disclosure to the regulator, consultants experienced in regulatory remediation can guide you on the proper communication and corrective action plan. In some cases, having a well-known consulting or law firm involved can lend credibility – regulators may take comfort that the firm has supported your compliance efforts (though, of course, ultimate responsibility stays with you). Consultants are also valuable if you have to respond to regulatory queries or findings: they can assist in formulating responses and action plans that adequately address the concerns.
In summary, consulting services act as force multipliers and expert guides. They are especially helpful for organizations that don’t have large in-house compliance project teams or that want reassurance through expert validation of their approach. By leveraging their specialized knowledge and project experience, you can accelerate compliance, avoid pitfalls known from PSD2, and adopt solutions that are proven elsewhere. The key is to integrate consultants properly: ensure knowledge transfer so that when their engagement ends, your team can sustain compliance. Consultants, internal audit, and external audit each cover different facets – if internal audit is the independent checker, external audit the certifier, then consultants are the strategists and implementers. When all three coordinate well, the organization stands in a strong position to meet PSD3 obligations effectively and efficiently.
5. Technical Requirements (API Security, Data Sharing, Authentication, etc.)
PSD3 and the accompanying PSR introduce a range of technical requirements aimed at ensuring secure, efficient, and interoperable payment services. Key areas of technical focus include API security and performance, data sharing mechanisms (open banking interfaces), and authentication protocols, among others such as digital resilience and data protection. Below is an overview of these technical requirements:
Under PSD2, banks were required to provide dedicated APIs for third-party providers (TPPs) to access payment accounts, but the performance and consistency of these APIs became a pain point. PSD3 squarely addresses API reliability and security:
Secure Communication and Authorization: PSD3 mandates that communication between TPPs and account-holding institutions (ASPSPs, typically banks) occurs through secure channels using strong encryption and standardized protocols. This includes enforcing TLS encryption for all API traffic and mutual authentication using eIDAS certificates or similar, as was required under PSD2’s RTS. Banks must ensure that only authorized TPPs (those with a valid license and certificate) can access customer data via APIs, and that each API call is properly authenticated and authorized with the customer’s consent token. The concept of OAuth 2.0 with secure grant flows is likely to remain the backbone of API authorization. PSD3 may also push for more fine-grained scopes in API permissions, meaning APIs should enforce least-privilege (e.g., a TPP with AISP role can’t initiate payments). On security, PSD3 will also bring alignment with the Cybersecurity Act (DORA) obligations: secure coding practices, regular penetration testing of interfaces, and robust incident detection for API endpoints will be expected.
Removal of Obstacles and Fallbacks: One major technical shift is PSD3’s elimination of the requirement for a “fallback interface.” Under PSD2, if a bank’s API failed or was underperforming, TPPs could be allowed to use the customer web interface as a backup. PSD3 proposes to remove this fallback option, effectively saying that the primary API must be good enough to negate the need for alternatives. Technically, this means banks can no longer rely on just offering a screen-scraping contingency; they must put all effort into making their APIs robust. PSD3/PSR also clarifies what constitutes an “obstacle” to TPP access – for example, requiring overly frequent re-authentication or presenting CAPTCHAs that TPPs can’t handle were considered obstacles under PSD2 EBA opinions. Banks will need to ensure their APIs avoid such hurdles: things like providing all data through the API that is available to the user via online banking (no missing data fields), and not imposing unjustified delays or additional authentication beyond what PSD3 allows. Essentially, TPPs should have as seamless an experience as the end-user would on the bank’s own interface.
Performance and Availability Standards: To professionalize open banking, PSD3 sets concrete expectations on API performance. As noted, targets around uptime (e.g., >=99% availability) and response times (e.g., median response under 1 second for account info, and say under 5 seconds even at peak for payment initiation) have been discussed. Banks will have to monitor and publish their API availability, and possibly report outages to competent authorities. If an API falls below certain performance thresholds, regulators might intervene (for instance, they could revoke an exemption or levy penalties). From a technical perspective, this requires banks to invest in scalable infrastructure – cloud deployments, load balancing, and perhaps regional failover systems to minimize downtime. They should also implement extensive API monitoring: synthetic tests, real-time alerts for slow responses, and incident management processes to fix issues quickly. A key new element may be transparent monitoring: PSD3 could require banks to produce metrics or dashboards accessible to TPPs showing the health of APIs (some jurisdictions started doing this in PSD2 era voluntarily or via industry coordination). TPPs and regulators gain confidence if they see, for instance, API uptime statistics and incident histories. Additionally, PSD3’s performance focus might include ensuring that APIs can handle high volumes (so banking-as-a-service or fintech apps can scale without hitting rate limit ceilings unexpectedly). Therefore, capacity planning and testing under stress conditions are technical must-dos.
Standardization and Interoperability: While PSD2 left implementation details largely to market-driven standards (like Berlin Group, UK Open Banking, etc.), PSD3 might push further towards harmonization. This could mean aligning on common data formats (JSON structures, ISO 20022 elements for payments) and possibly a unified API standard across the EU. From a technical angle, organizations may need to adjust their APIs to conform to new specs if a Europe-wide standard emerges. Even if not explicitly mandated, there’s momentum toward standardizing certain services (for example, a Confirmation of Payee/IBAN name-check service is being extended under PSD3). Technically, this might require banks to implement an API that allows verifying a payee’s name matches the account (to prevent misdirected payments), which many don’t currently have. Embracing standardized solutions (like those being developed for SEPA instant payments, etc.) will be part of compliance.
In summary, PSD3 raises the bar such that APIs must be secure, continuously available, and functionally rich enough to serve all intended open banking and open finance needs. Institutions should treat API infrastructure as mission-critical, on par with core banking systems, and invest accordingly.
Data Sharing and Open Banking
Data sharing in the open banking context (and soon, open finance) is a cornerstone of PSD3’s framework. Key technical requirements and changes include:
Extended Data Scope and Open Finance: PSD3 itself deals primarily with payment account data (the same scope as PSD2), but it arrives concurrently with a proposed Financial Data Access Regulation (open finance) that widens the net. In preparation, institutions should architect their APIs and consent systems to be extensible to other financial data like mortgages, savings, investments. Technically, this might involve adopting a modular API gateway that can plug in new data domains easily, and a unified consent management system that can handle various data types and granular permissions. For example, a bank might integrate its insurance or brokerage arm’s data into the same customer permission dashboard. While not all firms will have to provide non-payment data (only those active in those sectors), the trend suggests moving to a holistic API ecosystem. So, if you’re a bank that also offers wealth management, consider consolidating customer data access through a single gateway where possible, following the standards that open finance will lay down (likely similar in approach to open banking but with broader data schemas).
Consent and Permission Management: PSD3 places heavy emphasis on the customer’s control over data sharing. From a technical perspective, this means building or upgrading systems that capture, store, and enforce customer consents for third-party data access. Institutions should implement consent APIs and user interfaces: for instance, when a TPP requests access, the bank’s system should present to the customer exactly what data will be shared and for how long, and record their approval. A robust permission management solution includes: unique identifiers for each consent, time-stamping, and logging of every data access under that consent. PSD3 likely requires that customers can view and revoke consents at will – thus the bank’s online banking or mobile app should have a section (dashboard) listing all active consents, with an option to revoke. Technically, revocation should propagate immediately (TPP calls should then be denied once consent is withdrawn). This could be challenging if systems cached tokens – but compliance demands real-time updates. Using standards like OAuth 2.0, banks can implement short-lived tokens coupled with dynamic checks on consent status for each API call. Also, to be safe under GDPR and PSD3, banks must ensure once consent is revoked, any further data sharing ceases and TPPs are informed appropriately (some API specs include a “consent status check” endpoint for this).
Privacy and Data Protection by Design: Sharing more data means reinforcing data protection. PSD3 aligns with GDPR requirements, emphasizing data minimization and purpose limitation. Technical steps include masking or truncating sensitive data when full detail isn’t needed. For example, if a budgeting app only needs transaction categories and amounts, maybe detailed descriptors or personal info of counterparties should be masked. Another requirement is audit trails: every data access via APIs should be logged with who accessed what and when, enabling later audits or investigations. These logs must be secured and retained per regulatory guidelines. Data payloads should incorporate only what the TPP’s license permits (e.g., an AISP should not get payment initiation capability). Thus, robust access control lists and scopes must be enforced in the API gateway. Also consider data encryption at rest: any data retrieved and stored, even temporarily in your systems or in transit, should be properly encrypted to mitigate breaches. If PSD3 allows more data sharing beyond payments, multi-party data sharing agreements might be needed, and institutions should prepare to implement Data Usage Control technology – possibly something like secure APIs that tag data with usage rights or obligations (still evolving tech, but worth monitoring as open finance grows).
Reporting and Monitoring of Data Interfaces: PSD3 might introduce obligations for institutions to monitor and report API metrics (as mentioned, performance, downtime, error rates) and possibly TPP interactions (like number of successful vs failed authentications, or unusual access patterns). Technical teams should implement monitoring solutions that can generate these reports easily. For instance, build into the API platform the ability to compile monthly statistics for regulator reporting, such as how many times did ASPSP apply SCA for AISP access and how often consents were revoked. Such monitoring can also serve security: unusual spikes in data requests might indicate a malfunctioning TPP or even a security issue.
In essence, data sharing under PSD3 will be about trust and seamlessness: customers should trust that their data flows are secure and fully under their control, while TPPs should experience smooth integration and consistent data outputs. Achieving both requires diligent technical planning and execution on the bank/PSP side.
Strong Customer Authentication (SCA) and Identity Verification
Strong Customer Authentication – ensuring a user is who they claim to be using multifactor methods – remains central under PSD3, with refinements:
Scope and Exemptions Clarified: PSD3 clarifies circumstances under which SCA is or isn’t required. This has technical implications for authentication flows. For example, merchant-initiated transactions (MITs) (like a subscription charge) can be exempt from SCA, but PSD3 will likely require mechanisms to protect the customer (e.g., prior mandate and fraud monitoring). So your systems should identify MITs (perhaps via transaction flags or special processing codes) and handle them differently: authorize without an SCA challenge, yet maybe send a notification to the customer as a safety measure. Another example: contactless payments – PSD2 allowed certain counts/amounts of contactless taps before SCA triggers; PSD3 might raise limits or standardize them across the EU. Terminals and card issuers will need firmware/software updates to align with any new limits (say the single payment limit becomes €100 across EU, or the cumulative limit changes). Processors should be ready to adjust those counters.
Improved SCA Methods and Accessibility: PSD3 encourages more advanced and user-friendly authentication methods. Biometric authentication is a focus – banks and wallets should incorporate options like fingerprint, facial recognition, voice, or behavioral biometrics as part of SCA (with fallback options). Technically, this might involve integrating device biometrics via standards like FIDO2/WebAuthn for web and app logins. Also crucial is ensuring that SCA methods are not reliant on a single channel – e.g., if a customer doesn’t have a smartphone, they might use a hardware token or a desktop-based app. Institutions should diversify authentication offerings to cater to different customer needs (this also aligns with PSD3’s requirement of methods “adapted to their needs” including for those without smartphones). For example, some banks issue Bluetooth or USB tokens for customers who prefer not to use phones. Another aspect is no single point of failure – PSD3 says SCA methods should not depend on one technology or device, so if your mobile app is the primary SCA tool, have a backup like SMS-OTP or customer call for emergencies (though SMS OTP is less secure, it may remain a backup for those truly unable to use other means).
Transaction Risk Analysis (TRA) and Real-Time Fraud Detection: PSD3 continues to allow risk-based authentication – not every transaction may need SCA if it’s low-risk, but it likely tightens the rules around it. Under PSD2, to waive SCA, PSPs had to keep fraud rates below certain thresholds and undergo audits. PSD3 might update thresholds or require even more rigorous real-time fraud monitoring to justify exemptions. Technically, PSPs that employ TRA need to enhance their fraud engines: use machine learning models, incorporate more data (device ID, geolocation, spending patterns) in risk scoring, and be prepared for PSD3 possibly expanding the data that must be checked (e.g., consulting databases of known mule accounts or compromised devices). If the risk engine flags a transaction as unusual, it must seamlessly trigger SCA even if normally exempt, which means your payment flow systems must be integrated with your risk engine in real-time. Logging these decisions and outcomes is vital for both compliance and the required external audits of the TRA models. Also, PSD3 may require that if a PSP’s fraud rate goes above threshold, they must revert to full SCA usage until fixed. So technically you should have controls to auto-adjust SCA rules if risk KPIs degrade – say, temporarily disable certain exemptions if fraud levels spike.
Delegated Authentication and Liability: PSD3 acknowledges scenarios like delegated authentication (e.g., when a card issuer delegates SCA to a wallet provider or merchant in some way). It treats it as outsourcing, meaning the bank/issuer remains responsible for proper authentication. Technically, if you’re a card issuer that allows a third-party wallet to authenticate the cardholder (like storing your card in a mobile wallet and using the wallet’s biometrics), you need to ensure that the wallet’s authentication mechanism meets SCA standards at enrollment and use. This might involve security evaluations or certifications of the third party’s app and processes. Also, you’d need agreements about data sharing (e.g., the wallet tells you a successful auth event ID). Liability rules in PSD3 make it clear that if the third party fails to perform SCA correctly and fraud happens, you (the issuer) could be liable. So from a risk standpoint, issuers must carefully vet and monitor any third-party auth they rely on. This may encourage adoption of standards like 3-D Secure 2.x for card payments, which supports delegated auth flows under network programs with proper tokens and attestation.
User Experience and Multi-Channel Consistency: A technical yet user-facing requirement is ensuring SCA flows are consistent and user-friendly across channels. For example, if a user can approve a login via mobile app push notification or using a physical token as alternatives, both should grant access equivalently. Banks should integrate their SCA solutions so that a user can choose their preferred method (where applicable) and have backup methods registered. For accessibility: include support for screen readers in app authentication, voice-based navigation for IVR authentication (for phone banking), and one-time passcodes that consider users with disabilities (like allowing copy-paste from SMS for those who can’t type well). Testing SCA with a diverse user group is advisable to catch any shortcomings. Regulators are conscious of inclusivity: PSD3’s insistence that no user group is left behind means that if your digital channel is the only way to bank, you must cater to those who maybe can’t use a smartphone or have other impairments
To sum up, PSD3’s technical requirements around SCA and identity verification push providers to deliver friction-right, secure authentication: frictionless when possible (through biometrics, TRA for low risks) but strong when needed. Technically, this demands integrating advanced authentication tech, real-time analytics, and keeping a flexible yet robust auth architecture.
Other Technical and Operational Resilience Requirements
Beyond the headline items (APIs, data, SCA), PSD3 interacts with broader digital operational requirements:
Digital Operational Resilience (DORA) Alignment: The EU’s DORA imposes requirements on ICT risk management, testing, and incident reporting for financial entities. Payment firms in scope of DORA will have to follow those (operational risk management frameworks, regular penetration testing, oversight of critical ICT third parties). PSD3 doesn’t duplicate DORA but you should ensure that your PSD3 compliance effort and DORA compliance effort are coordinated. For example, PSD3 may require certain continuity plans (like for cash services continuity, etc.), and DORA requires robust BCP and disaster recovery testing. It’s efficient to treat them in unison: ensure your IT continuity covers PSD3 scenarios (like what if your API channel is down – have a recovery plan even if fallback is not allowed, perhaps communicating to TPPs and restoring quickly).
Reporting and Data Analytics: PSD3 could introduce new reporting (for example, statistics on fraud, performance, complaints handling times, etc.). Ensure your systems can capture the needed data points and generate compliant reports. Many banks had to adapt systems to report PSD2 operational and fraud data to authorities annually. Expect that continue or expand. It’s technical in the sense of data engineering – pulling logs from multiple systems (fraud engine, customer support, etc.) to produce the aggregated info.
Technology Providers and Outsourcing: Many payment institutions rely on third-party tech providers (for core banking, for API solutions, etc.). PSD3 and DORA both put a spotlight on outsourcing risk management. You should technically and contractually ensure that your providers comply with these regulations too. This might mean building interface solutions for them to provide you necessary data (like if a cloud provider hosts your API, you need from them the uptime stats for reporting; or ensuring you have right to audit clauses, etc.). You might also consider multi-vendor strategies or backup providers for critical services to reduce single points of failure.
In conclusion, meeting PSD3’s technical requirements calls for a multi-faceted upgrade to your technology landscape – focusing on making systems more secure, more open (standardized), and more resilient. Organizations should allocate sufficient time and resources to these technical workstreams, as they often prove to be the most complex and time-consuming part of regulatory compliance. However, the payoff is that you’re not just compliant – you’re running on better, more modern technology that can enhance your competitive position and reliability in the market.
6. Recommended Roadmap and Timeline for Institutions
Implementing PSD3 compliance should be approached as a structured program with clear phases and timelines. Although exact dates depend on the EU legislative process and national transposition, institutions can construct a provisional roadmap. Below is a recommended high-level timeline and milestones for PSD3 compliance, addressing what tasks to accomplish in each period. (This timeline assumes PSD3 finalization around end of 2024, with an ~18-month implementation period into 2026 as indicated by legislative projections.)
2023 – Early 2024: Awareness and Initial Planning – Preparation Phase.
Regulatory Monitoring: Closely follow PSD3/PSR legislative progress (e.g., final directive text, EBA technical advice, any early guidance or Q&As) and sensitize your leadership to upcoming changes.
Impact Assessment: Form a PSD3 working group and conduct a high-level impact analysis to secure budget. Begin the detailed current state vs. PSD3 requirements gap analysis (as outlined in Section 2).
Strategic Planning: Identify key projects and resources needed. Draft an initial compliance plan including major workstreams like IT changes, policy updates, training, etc., along with cost estimates. Engage with industry associations or legal counsel for interpretations of draft requirements – this input will refine your plan.
Interim Actions: Where possible, address obvious gaps early if they are clear “no regrets” moves – for instance, improving API uptime or starting work on a wind-down plan, since these are beneficial even if PSD3 details tweak slightly.
Mid/Late 2024: Project Initiation and Design – Mobilization Phase.
Resource Allocation: By now, it’s likely the final PSD3 text will be known. Secure formal approval of the PSD3 compliance project and allocate dedicated budget and staff. Consider hiring temporary specialists or engaging consultants for surge capacity in complex areas.
Project Governance: Establish a governance structure – e.g., a steering committee with executives from IT, operations, compliance, and business lines. Set up regular project management routines (status reports, risk registers).
Solution Design: Begin detailed solution design for each workstream. Examples: Draft the architecture for API enhancements (with vendor selection if needed for new API management tools); design updated customer journeys for SCA and consent flows; outline new policy documents (perhaps get templates from consultants or industry examples); plan data migration if any (like consolidating records for reporting).
Stakeholder Communication: Internally, communicate the project plan across departments so everyone knows changes are coming. Externally, if you rely on vendors, notify them you’ll need updates from them (e.g., core banking software providers might need to issue a PSD3 compliance patch – start that conversation now).
2025: Implementation and Testing – Execution Phase.
Q1–Q2 2025: Depending on how quickly EU institutions adopt PSD3, member states might start transposing it. Use this period to build and develop required changes. IT teams should be coding and configuring systems (e.g., implementing new API endpoints, upgrading authentication servers, integrating fraud analytics). Policy and process owners should be rewriting documents (terms & conditions, user guides, internal manuals). Consider an agile approach: prioritize core compliance-critical changes first and iterative rollout.
Q3 2025: Begin internal testing of changes. This includes unit testing by developers and functional testing by business users or QA teams. For tech like SCA or APIs, also do security testing (penetration tests, vulnerability scans) and performance testing (simulate heavy API load to ensure it meets targets). Start training programs for staff on new procedures and systems. By this time, regulators or industry groups might offer sandbox or dummy interfaces; participate in those to validate interoperability (e.g., test your new API with some friendly third parties or open banking sandbox tools).
Q4 2025: Commence user acceptance testing (UAT) and pilot deployments. For example, roll out the new mobile app with PSD3-compliant SCA to employees or a small customer segment to gather feedback. Iron out any bugs or user experience issues. Also, audit readiness: have internal audit or compliance do a mock audit against PSD3 requirements now—checking, for example, if all necessary records are being captured, or if new processes achieve compliance outcomes (like refunds within required time). Address any findings. By end of 2025, aim to have most systems ready in a pre-production state. Additionally, start finalizing documentation that regulators might want to see immediately when PSD3 goes live, such as updated risk assessments, model validations (if you use TRA, ensure you have an audit report if possible, as per PSD2 practice), and compliance attestations for your board to sign off.
Early/Mid 2026: Transition and Go-Live – Compliance Phase.
Regulatory Deadline: It’s anticipated that the PSD3 directive’s transposition deadline and PSR application will fall around mid-2026, meaning requirements become law for firms at that point. Leading up to this, in early 2026, ensure any final national guidance is incorporated (e.g., if your regulator publishes specific rules or interpretations, adapt accordingly).
Go/No-Go Checks: Do a final readiness assessment at least a couple of months before the deadline. All critical functions should be tested end-to-end. If third parties (like TPPs) need to adjust to your changes (say you’re decommissioning a fallback interface or introducing a new API version), communicate and coordinate a cut-over plan with them well in advance to avoid disruption.
Launch: Deploy updated systems and processes into production ahead of or by the regulatory deadline. For example, release the new SCA flow in your banking app, activate the new API with all required features, and start using updated policies in daily operations. Closely monitor the initial period: set up a “war room” or dedicated monitoring team for the first few weeks to rapidly respond to any issues (like unexpected error rates on APIs, or customer confusion with the new login process).
Regulator Engagement: Some regulators may require a formal notification or self-certification of compliance when PSD3 goes live. Prepare a compliance report or at least an internal memo documenting how you have complied with each major PSD3 area – this can be shared if regulators inquire or during the next supervisory meeting. Also, if there are known gaps that couldn’t be fully closed by deadline (despite best efforts), proactively inform the regulator with an explanation and a short-term remediation plan. Transparency can earn goodwill and avoid enforcement, provided the gaps are minor and being fixed.
Late 2026 – 2027: Post-Implementation and Continuous Improvement – Embedding Phase.
External Audit & Certification: Many firms will undergo their first external audits under the PSD3 regime during this period (e.g., 2026 financial audit or dedicated compliance audits). Be prepared to provide evidence and walkthroughs of your new processes to auditors. Address any issues they raise promptly.
Operationalizing New Capabilities: Use the investment in PSD3 compliance to your advantage. For instance, if your API is now high-performing, consider leveraging it for new business models (maybe premium APIs or partnerships). If SCA is smoother, highlight it in your marketing as a security feature.
Monitor Effectiveness: Begin collecting data on key indicators: fraud rates (did the new measures reduce fraud?), API usage (are more TPPs consuming data after improvements?), customer feedback (any complaints about the new fees transparency or authentication?). Fine-tune processes accordingly. Compliance is not static – regulators will also be monitoring industry outcomes and could tweak rules or expectations. Maintain a dialogue through industry forums.
Future Planning: Looking beyond PSD3, consider upcoming EU initiatives that might piggyback (like instant payments regulation implementation, the digital euro exploration, extended open finance). The roadmap shouldn’t end at checking the PSD3 box, but rather integrate into a continuous innovation and compliance strategy.
Summary Timeline (illustrative):
2023: Initiate PSD3 impact analysis, secure management awareness and initial budget.
2024: Formulate detailed plan, mobilize team, and begin solution design (once PSD3 text is finalized). Possibly start early development on obvious requirements (e.g., API upgrades).
2025: Execute development and process changes; complete major build by year-end. Conduct comprehensive testing and employee training; engage internal/external auditors for dry runs.
2026: Roll out changes in production in advance of legal deadline (expected mid-year). Ensure full compliance by deadline; respond to any teething issues. Provide compliance attestation/documentation to regulators as needed.
2027: Enter “business as usual” under PSD3 rules. Evaluate the program’s success and integrate lessons learned into future regulatory projects (like open finance, etc.).
Institutions should tailor this roadmap to their size and complexity. Larger banks might have parallel projects in multiple countries (coordinate group-wide), whereas smaller fintechs might compress activities but should not skip critical testing or oversight steps. The key is starting early and maintaining momentum, as the window to implement could be around 18-24 months from final rulesdotfile.com. Also, building some buffer into the timeline for unexpected delays (especially IT development challenges or awaiting vendor updates) is prudent.
Finally, keep communication flowing: regularly update senior management on progress and any risks to timeline or budget, so there are no surprises. By following a structured roadmap and timeline, institutions can navigate the PSD3 compliance journey in an organized manner, ultimately achieving compliance on time and reaping the benefits of a stronger, more innovative payment service offering.
