02 Sep 2025

A safe and future-proof digital payments ecosystem: Recommendations for PSR and PSD3 trilogues

Executive summary 

DIGITALEUROPE welcomes the efforts promoted by the co-legislators and the European Commission to promote a safe digital payment ecosystem through the proposed Payment Service Regulation (PSR) and Payment Service Directive 3 (PSD3).

The PSR has the potential to future-proof the payment ecosystem against evolving fraud risks, ensuring robust consumer protection. At the same time, it can empower Payment Service Providers (PSPs) to deliver innovative payment solutions that enhance user experience and trust. 

As trilogue negotiations progress, DIGITALEUROPE urges EU co-legislators to adopt the following recommendations:  

  • Fraud: the PSR should strengthen fraud prevention by establishing clear, objective rules on authorisation, liability, Strong Customer Authentication (SCA), and transaction monitoring, whilst avoiding disproportionate burdens on PSPs. A cross-sectoral, risk-based approach with defined responsibilities for all stakeholders, and a multi-stakeholder platform for fraud prevention, are essential to protect consumers and ensure a secure payments ecosystem. 
  • Regulatory alignment: the PSR must be consistent with the General Data Protection Regulation (GDPR), the Instant Payments Regulation (IPR), the proposed Framework for Financial Data Access (FIDA) regulation, the Digital Operational Resilience Act (DORA), the Anti-Money Laundering Regulation (AMLR) and the Digital Service Act (DSA).
Download the full document
For more information, please contact:
Federico Di Benedetto
Policy Manager for Digital Transformation of Financial Services
Vincenzo Renda
Director for Digital Transformation Policy
Alberto Di Felice
Policy and Legal Counsel
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