Your consultation notes that the Payments Services Directive has been taking shape over a long time scale and included five official drafts before the Commission recommended the Directive and passed it on to the Council of Ministers and European Parliament.
The ACT has been following all these stages and has already contributed to the discussions on policy and drafting through feedback to HM Treasury and the Commission or via the European Associations of Corporate Treasurers.
In recent weeks the shape of the directive has evolved significantly from the Commission adopted version, and therefore this response is probably not the appropriate place to make detailed drafting points.
The ACT believes the PSD is a helpful piece of legislation which will certainly go a long way towards resolving some of the key problems identified with the EU payments systems, namely fragmentation across the EU, inefficiencies and uncertainties in the current systems, and lack of competition. Although we have concerns over some of the details in the Directive, we are supportive of the overall purpose and direction of the proposals.
We know the HM Treasury has been active in consulting with all sides of payments industry and making representations through the various European channels. We appreciate that active engagement.
