Nets is in favour of a one-step approach (option b) but with an entry into force date following the PSD 2.
The two step approach has at least the following weaknesses:
• There is a risk of implementing measures defined in the current guidelines that will not be compliant with future guidelines. Such a risk will impose extra (and unnecessary) cost and workload to PSPs, and potentially also confusion and inconvenience to the consumers and e-merchants.
• The guidelines should be enforceable to all PSPs in the value chain, including payment initiation service providers – the latter being regulated when the PSD 2 comes into force.
In general Nets prefer to operate under firm guidelines, and not in an environment where assumptions are to be made. We understand that quite a number of issues still are under debate in the PSD 2 regulation, making it uncertain what the outcome will be. Our experience is that such regulation will take at least a year for the PSPs to implement.
We strongly recommend to follow a one-step approach, and that the ap-proach is based on the definitive and final text of the PSD 2 and the im-plementation date of the Guidelines should take into account an appropri-ate time frame starting from the effective date of adoption of this text.