Response to consultation on draft Guidelines on the limited network exclusion under PSD2
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Furthermore, Guideline 2.2 is suggesting the single Member State Authority to act each in a different way, plus adding a number of subjective criteria of evaluation, such as the geographical area, the number of users, the target-customers, etc. If the aim of these guidelines is to support EU markets, support authorities and support companies, the drivers should be simple indications, consistent restrictions and clear and transparent rules for the end users.
Q1. Do you have comments on Guideline 1 on the specific payment instruments under Article 3(k) of PSD2?
NoQ2. Do you have comments on Guideline 2 on the limited network of service providers under Article 3(k)(i) of PSD2?
If the purpose of this consultation is to provide authorities with objective criteria to guide assessments and regulations in a European Union that aims at being an entity characterized by markets with similar rules, and if the whole world has become a global market and if this regulation is looking at both physical and electronically retailers, why are we still speaking of geographical boundaries? Article 3 (k) (i) provides the restricted number of providers as a criteria, why should the authority make an evaluation based on the geographical area for the provision of the goods/services? Geographical area in 2021, by definition, is global. And so should be considered by any authority looking at regulating, still supporting, the European market. In Europe the geographical area in regulations should be Europe, no doubt.Furthermore, Guideline 2.2 is suggesting the single Member State Authority to act each in a different way, plus adding a number of subjective criteria of evaluation, such as the geographical area, the number of users, the target-customers, etc. If the aim of these guidelines is to support EU markets, support authorities and support companies, the drivers should be simple indications, consistent restrictions and clear and transparent rules for the end users.