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Payments & FinTech Lawyer

Voluntary guidelines and encouraged market behaviours under PSD2 in the ‘transitional period’

UK Finance, the Financial Data and Technology Association, techUK and the Electronic Money Association have jointly published voluntary guidelines and encouraged market behaviours (the ‘Guidelines’) under the EU’s revised Payment Services Directive (‘PSD2’). The main aims of the Guidelines are to “foster a collaborative and cooperative industry ecosystem around account information services and payment initiation services,” to increase customer protection in areas such as “credential sharing” and “screen scraping” and to promote the use of PSD2 compliant APIs, in accordance with industry aims. The Guidelines’ application extends to all firms that both operate in the UK and are authorised or registered under PSD2 as Account Servicing Payment Service Providers (‘ASPSPs’), Account Information Service Providers (‘AISPs’) or Payment Initiation Service Providers (‘PISPs’) (as well as those pre-12 January 2016 ‘grace period’ firms - see below). Ben Regnard-Weinrabe, Heenal Vasu, Martin Dowdall and Hannah Pack of Allen & Overy LLP, discuss the Guidelines in detail and why they are important.

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