The UK Cards Association (‘UK Cards’) preferred starting point based on the two options presented, would be to pursue option (a) as part of a ‘two-step approach’ going forward.

Based on the simple premise that it would be non-sensical and unsatisfactory in trying to pre-empt or anticipate the final outcome of the PSD 2 negotiations as they currently stand.

We would instead align any implementation period to what the Payments Council has proposed; awaiting finalisation of the PSD 2 text and then review of the SecuRe Pay recommendations against these new requirements, before issuing draft guildines and/or technical standards allowing for a longer period of implementation.

More generally, UK Cards has repeatedly asserted its concerns in previous responses at the EBA and ECB’s overly prescriptive approach; demonstrated once more by reference to the supporting draft guidelines which we believe will likely hinder innovation rather than support it.

UK Cards has commonly stated that a better policy would be to work towards guidance being based on a set of achievable outcomes rather than through prescribed sets of rules.