PSD3/PSR: a new phase in the financial services landscape

In the rapidly changing landscape of financial services, the implementation of new legislation is on the horizon. Notably, the third Payment Services Directive (PSD3) and the new Payment Services Regulation (PSR) are set to reshape the payments landscape within the financial sector.

In 2019, PSD2 established a regulatory framework that strengthened security, enhanced consumer rights, and opened the door to greater competition and innovation by enabling authorized third-party providers to access payment accounts with consumer consent. This directive facilitated the development of new financial services and products, such as account aggregation and payment initiation services, while maintaining stringent security and customer consent protocols.

With PSD3 and PSR, the European Commission is taking the next step: aiming to close regulatory gaps, further enable access for non-bank providers, and strengthen consumer rights; with finalization expected by early 2026, and most provisions applying from end of 2027. These changes are not only about compliance: they are about ensuring trust, improving payment resilience, and levelling the playing field across the EU. 

While the new rules will primarily apply to regulated payment service providers, their effects will ripple through the broader financial ecosystem, including digital wallets, crypto-native firms seeking licenses, and other businesses embedding payments into their customer journeys. For both incumbents and challengers, this is a moment to reassess strategy, processes, and technology.

Key considerations for PSR/PSD3

Regulatory Compliance:

• Has a gap analysis been performed to identify areas needing adjustment to comply with PSD3/PSR?

• What steps must be taken to ensure our organization remains compliant with PSD3/PSR requirements, including updates to internal policies? 

• How do we establish a robust monitoring system to keep up with regulatory changes and ensure timely compliance?

Strategic positioning:

• How will PSD3/PSR impact our existing business models, and how can we strategically position ourselves in the market?

Technological adaptations:

• Does our current IT infrastructure align with the PSD3/PSR requirements?

• What technological improvements do we need to make first to become compliant? Consider, for example, the early testing of current API interfaces. 

Customer-facing processes:

• Are all our customer processes and products PSD3/PSR-proof? 

• Where are we most at risk of fraud or liability issues? 

Innovation opportunities: 

• Are there any new business opportunities and product expansions?

• How can we leverage enhanced access to payment data to develop innovative financial products tailored to customer-specific needs? 

How we can support you

Our dedicated financial services advisory team stands ready to assist your organization in navigating this evolving regulatory environment.  Our multidisciplinary team brings a wealth of specialized expertise to help your company manage every aspect of PSD3 and PSR implementation. From identifying challenges to uncovering opportunities, we provide comprehensive guidance tailored to your needs.