Up to speed on the EU’s revised Payment Service Directive

Catalyst or threat?

The strategic implications of PSD2 for Europe’s banks

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The Future of Banking

Innovation & Disruption in light of the revised European Payment Services Directive (PSD2)

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Define the new era of consumer-friendly payment services

The revised Payment Service Directive (PSD2) is set to completely reshape the payment landscape, not just in the EU, but in Switzerland as well. Established banks and financial services players will have to be on their toes: PSD2 creates huge opportunities, but also opens the market to new players with highly disruptive intentions. We help banks and other payment service providers proactively address the challenges and capitalise on the opportunities of the new directive.

The new legislative framework is primarily designed to create a single integrated market for payment services by standardising the regulations for banks and the new PSPs (payment service providers) emerging in the wake of digitisation. PSD2 will break down the entry barriers, help strengthen system security, enable new payment services, and ensure transparency and fair competition to the benefit of consumers.

PSD2 introduces significant innovation in legal and compliance, technology and security, and defines new roles and services in the payments market. Our team brings extensive legal, regulatory and compliance experience in financial services to help clients negotiate the risks and capitalise on the opportunities created by the new rules.


PSD2 will drive radical change. Click on the keywords to find out how:

PSD2 extends the scope of the regulations to cover both ‘one leg’ transactions and transactions in non-EU currencies. It also introduces new payment services (payment initiation, account information and funds checking).

PSD2 introduces new market players called third party payment providers (TPPs). These fall into two categories: payment initiation service providers (PISPs) and account information service providers (AISPs).

PSD2 extends the regulations on the responsibilities of TPPs.

PSD2 harmonises the security requirements and authentication procedures, making Strong Customer Authentication (SCA) the mandatory standard for all electronic payment transactions.

PSD2 extends the shared pricing principle and aligns the application of additional fees with the new MIF regulation.

PSD2 limits the exceptions granted to commercial agents, limited networks, telecom operators and independent ATM operators.





Click on the keywords to find out how PSD2 paves the way for new services and a new customer experience:

Innovative payment services for merchants as an alternative to cards

Access to information through a single touchpoint or app for integrated and aggregated monitoring of accounts and expenses

Withdrawal from different accounts using NFC technology, and the facility to compare the commissions applied

Geolocation and integration of offers, discounts, coupons and conventions

Instantaneous payments via mobile wallet on many p2p accounts and to operators with advanced features

White-label cards decoupled from payment accounts


What we can do for you

Our dedicated team of professionals has the fully integrated, multidisciplinary skills to help you respond to the entire range of issues related to PSD2. You also benefit from full support and continuous dialogue with the network and the market, and ongoing monitoring of regulatory updates (including, if you choose, a periodic email newsletter containing legal interpretations).

Here’s a brief summary of the main areas we can help you with:

Quick assessment

In the first assessment phase we help you anticipate the market, develop strategic opportunities and prevent any possible issues resulting from regulatory and business developments.

Financial statement & regulatory audit

The auditing of annual reports and financial information is one of our core competencies – though naturally we can offer our clients much more. 

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Scope definition

We help you define the scope of the services, products, processes and applications affected. This also means you’ll get guidance on interpreting the PSD2 regulations.

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Gap and impacts analysis

We do a high-level gap analysis with respect of the requirements previously covered by PSD, including local regulations, and taking the relevant legal and IT issues, processes and business areas into account.

We qualitatively determine the impacts in each area to give you a detailed picture of the critical gaps, actors and organisational structures involved, and an idea of the level of impact (high, medium or low).

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Opportunity analysis

We give you access to international surveys and comparisons with market benchmarks at EU level. We help you do an initial analysis of the new business opportunities and services and estimate the economic potential.

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Activities to address

We help you define an action plan on a macro basis, including a prior estimate of the timeline and effort involved. We’ll also help you address the critical issues with workgroups and industry associations.

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Research and insights 

How banks are gearing up for PSD2

How banks are gearing up for PSD2

Banks don’t have much time left to make sure they’re compliant with the EU’s revised Payment Services Directive (PSD2). However, for many financial institutions, PSD2 is more than just a compliance exercise. It will Impact banks’ strategic positioning and significantly change their risk profile as they interact with third parties. Since Switzerland is not a member of the EEA, PSD2 isn’t directly applicable in this country. But given that Switzerland is a member of SEPA (the Single Euro Payments Area), in the future it will be required to demonstrate that national rules similar to PSD2 are in place. There will also be heavy pressure on Swiss banks from the client side to open up their architecture vis-à-vis third parties.


Our experts

Dr. Günther Dobrauz

Leader PwC Legal Switzerland, Zurich

+41 58 792 14 97


Philipp Rosenauer

Manager, Legal FS Regulatory and Compliance Services, Zurich

+41 58 792 18 56


Michael Taschner

Senior Manager, Legal FS Regulatory and Compliance Services, Zurich

+41 58 792 10 87


Murat Güden

Advisory Director, Zurich

+41 58 792 16 49


Silvan Lang

Director Financial Services Strategy Consulting, Zurich

+41 58 792 14 05