PSD2 re-registration deadline on 12 October – 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.

Firms that are currently registered by the FCA as Small Payment Institutions (SPIs) and Small Electronic Money Institutions (SEMIs) will need to ensure that they apply to the FCA by 12 October 2018 for re-registration to continue undertaking regulated payment services or e-money  activities under the PSD2 regime.

The revised Directive has strengthened the requirements for firms to maintain documented policies and procedures as well as implementing an effective infrastructure of systems and controls. This will need to include customer authentication processes, procedures for incident reporting, complaint handling, management of sensitive payment data, a 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 in scope of the Payment Services legislation with the FCA application process,  the implementation of additional policies and internal documentation and with maintaining compliance with PSD2 on an ongoing basis.

The 12 October 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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