The legislative proposal on PSD2 was sent to the Dutch Lower House on 23 October 2017. In the cover letter, the Minister of Finance writes that the scheduled implementation date of 13 January 2018 is no longer realistic. The implementation of PSD2 is expected to take place in the spring of 2018. This means both the licensing by DNB and the entry into force of new obligations for license holders will be delayed. At DNB's seminar on 26 September 2017 we explained this situation in more detail.
It is currently unknown when institutions can start applying for a licence. The most up-to-date information is available on the special Dutch-only PSD2 page on DNB's website. This page also provides information about existing licence holders, new payment services, commercial agents and electronic trading platforms.
Introduction of new obligations for licence holders
Licensed payment service providers will be subject to additional rules following the transposition of PSD2 into Dutch legislation. The date from which current licence holders will have to meet the new requirements of PSD2 has not yet been determined. This partly depends on the implementation of PSD2 into Dutch rules and regulations and the introduction of regulatory technical standards and guidelines. We will decide how that date must be established once the enactment process offers sufficient clarity.
Seminar and further information
On 26 September 2017, we hosted a seminar on PSD2 to inform the sector about requirements and procedures surrounding licensing and declarations of no-objection under the legislation implementing PSD2. The Ministry of Finance addressed the expected delays during the seminar, which was well-attended. Clearly, payment institutions, banks, FinTech operators, consultants and law firms are anxious to know more about the introduction of the legislation, and the requirements and procedures it entails. We aim to answer those questions that could not yet be answered during the seminar on our dedicated PSD2 web page.
We sent out a questionnaire to banks and payment institutions in the summer of 2017 to gain more insight into the changes they expect PSD2 to bring. A small number of institutions indicated they have concrete plans to offer new services, such as payment initiation services (service 7) and account information services (service 8). Even so, all respondents agree that they expect PSD2 to attract many players. Similarly, they unanimously expect FinTech and bigtech players to express the greatest interest in offering new services, and they expect interest for account information services to be greater than for payment initiation services.
Information need and risks
The questionnaire also revealed that most questions banks have are about the access they should grant other parties to their customers' accounts. The challenge they are up against is how to inform their customers about the various services. For their part, payment institutions view access to current accounts as a risk, due to unclarity about their relations with banks. They face questions in the areas of communications, incidents, liability and information security. The respondents also commented that information security will be the biggest challenge for both types of service.