EACT Comments on the Commission Proposal for Payment Services Directive II

The EACT has published a position paper on the Commission's proposal for a revised Payment Services Directive. The position focuses on the need to ensure that corporates' centralised payments operations remain out of scope of the Directive as the intra-group exemption is currently not applied coherently across Member States and the revision introduces some further uncertainty as to whether corporate in house banks or shared services centres could be regarded as falling within the scope of the Directive. We also argue that the changes proposed by the Commission to the unconditional refund right for direct debit transactions would be counterproductive and unfeasible to implement.