Things change, things stay the same: updating the FCA Approach Document for PSD2

The FCA has published a Feedback Statement (FS16/12) on the responses it received to its February Call for Input on its approach to the payment services regime.

The FCA intends to update the Payment Services Approach Document and chapter 15 of the Perimeter Guidance Manual to reflect PSD2.

This update will also:

  • produce a combined document covering its approach to payment services and e-money, rather than having two separate documents;
  • take into account recent market changes, such as new technologies and business models; and
  • aim to provide guidance on other relevant legislation or regulatory initiatives.

PSPs will want to ensure the FCA fully understands new technologies and business models. Engagement with the FCA is therefore key to ensure the revised Approach Document reflects the rapidly changing market. PSPs will also be concerned to ensure that updated guidance on existing legislation does not inadvertently call into question existing practices.

Next steps

HM Treasury is currently working on UK regulations to implement PSD2. These are behind schedule which has probably resulted in the FCA's rather vague timetable of consulting on guidance in 2017 and finalising as far as possible in advance of January 2018.

The gap between the finalised Approach Document and implementation date is likely to be short.

BCOBS must also be updated. As yet the FCA has not indicated the timing for this process but it must be on a similar timetable due to changes in scope.

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