(Note: the below is a high level review of certain potential issues and is not to be relied upon in any definitive manner nor as legal and/or regulatory advice).
It’s not a great start to the new year for the Commission. Its review of the current E-Money Directive (“EMD2”) has been postponed until some time later this year. This is on the back on previous delays, due partly to the late implementation of EMD2 by some Member States.
Why is the report important?
The Commission’s report is intended to cover the effectiveness of the E-Money Directive, as well as providing insights into any areas which will likely be the focus of any revision.
Its delay will be frustrating news to many in the industry, particularly as any revision should correctly dovetail the PSD and as the negotiations on PSD2 progress, it would be useful to review any proposed changes to EMD2 at the same time.