Question ID
2023_6750
Legal act
Directive 2015/2366/EU (PSD2)
Topic
Authorisation and registration
Article
1
COM Delegated or Implementing Acts/RTS/ITS/GLs/Recommendations
Not applicable
Article/Paragraph
n.a.
Type of submitter
Industry association
Subject matter
requirements for professional experience of representatives and board members of EMIs
Question

Dear Sir/Madam, 

 

In the process of licensing an EMI, the management of the company aplying for a licese is required to have certain professional qualifications: experience, clean record, good reputation,etc...

As PSD2 does not regulate this topic, each National Bank has set different requirments. The same pereon may be elidgible under the requirments of central bank of one country while not elidgible for another. Usually, the requirments are for banking and equivalent proffesional background and experience.  Profesionals with technology background (eg. Computer Science, blockchain, software development, AI, information management) are not elidgible.

However technology is one of the main drivers of innovation and competitiveness in both banks and fintech. 

 

In this regard, I have two questions: 

1. Is EBA discussing any harmonisation of requirments for profesional experience of managing teams of EMIs to be enforced in a new updated PSD2?

2. If yes, does EBA consider allowing technology related profesionals to hold management possitions in EMIs? 

 

Best regards, 

Filip Mutafis

 

Background on the question

I am an experienced proffesional with 25y backgroudn in providing various software solutions for banks and insurance companies as founder and managing partner of software development and consultancy company. I have a MSc degree in Computer Science.

Together with a team of two other proffesionals with banking experience we founded company that is applying for an EMI license. 

However, my profesional experience is not considered suitable for the BoD of the to-be-licenced entity, due to lack of relevant banking experience, as per the requirments of Bulgarian Central Bank. 

We have been informed that EBA is looking into harmonization of the requirments accross Europe and I am interested to know in what direction the regulation is expected to change. 

Submission date
Rejected publishing date
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Status
Rejected question