PSD2 re-authorisation deadline of 13 April - is your FCA application ready?

The Revised Payment Services Directive (PSD2) has been in effect since 13 January 2018, as implemented in the UK through the Payment Services Regulations 2017 (PSR 2017).  Types of businesses in scope include existing payment service providers and e-money issuers, but now also some firms that were previously exempt from regulation and those that plan to provide account information or payment initiation services.

Firms that are currently registered or authorised by the FCA as payment institutions or e-money institutions will need to ensure that they apply to the FCA to be re-registered or re-authorised by 13 April 2018 to continue undertaking these activities under the PSD2 regime. Only Small Payment Institutions have until 13 October 2018 to submit a new PSD2 application.

The revised Directive has strengthened the requirements for firms to maintain documented policies and procedures as well as implementing an effective infrastructure. This will need to include customer authentication processes, procedures for incident reporting, complaint handling, management of sensitive payment data, business continuity plan, a robust security policy - all to ensure that payment service users are granted appropriate protection.

At Moore Stephens, we have helped a number of firms with the FCA application process as well as the implementation of additional policies and internal documentation, and can also provide assistance with maintaining compliance with PSD2 on an ongoing basis.

The 13 April deadline is fast approaching, so if you need any help with your application pack or the additional information to be provided to the FCA, please feel free to contact our regulatory consulting team.

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