BT-REQ-3972 PSD3 Impacts v6(without crop marks) RL - Flipbook - Page 21
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HL | PSD3 Impacts
The Council Text has opted to leverage the
verification of payee requirements under the Instant
Payments Regulation, which amended the SEPA
Regulation and which are due to come into effect
in Q3 2025, applying them to payment transactions
that fall outside the scope of SEPA (e.g. e-money
transactions). Under the SEPA regime, there is
no ability for consumers to opt out; however, the
principles of liability to the PSU (and between the
PSPs) are similar.
What is the impact?
This will require ASPSPs to implement a
confirmation of payee service. In the UK, the service
was created by Pay.UK. If a market solution doesn’t
present itself, banks will be required to implement
their own solutions.
The requirement is not subject to the corporate
optout (although the SEPA Regulation, which the
Council Text looks to, does permit a certain amount
of flexibility in relation to corporate customers);
however, the notification period for a claim is.
If banks operating in the corporate space want to
limit their exposure to this new liability in the way
they currently do for unauthorised or defective
transactions, they will need to have their corporate
customer agree to the change in the scope of
the optout.
