In June this year, the European Commission published the Financial Data Access and Payments Package, which includes proposals for the new Payment Services Directive (PSD3), Payment Services Regulation (PSR), and the financial data access (FiDA) framework. The Association for Financial Markets in Europe (AFME) recently responded to the proposals, assessing that they have “the potential to enhance the way banks operate, encourage innovation, and support a more effective and efficient data ecosystem and payments system”.

The latest response paper follows one that was published in September last year that “set out building blocks for a competitive, innovative, secure, and consistent framework for EU data sharing”. AFME cites two areas of focus: implementation issues, and compensation.

All about data

Under implementation issues, AFME expresses support for limiting the scope of data to customer-provided data and transactional data, excluding inferred data. “Given the specific nature of wholesale and corporate clients and the services provided to them, data from these entities should not be included in the definition of customer data for the purpose of data sharing,” writes the report.  

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The association advocates for the strong regulation and supervision of financial information service providers (FISPs) to ensure that these entities do not exploit or misuse the sensitive consumer data that they have access to. In addition, it considers the requirement to share all data in real-time “disproportionately operationally burdensome and does not yield commensurate benefits”. Due to the “wide scope of data captured under FiDA”, AFME supports “the allowance of a limited and reasonable time lag in data sharing”.

Fair pay

Regarding compensation, AFME believes that it should be market driven to encourage investments in innovation and data infrastructure. The association considers the current proposed compensation cap to be “overly broad and liable to increase fragmentation in data markets and create asymmetries between different types of data holders”. It suggests that the cap be limited to small and micro enterprises.