Yapily Connect UAB

EU Legislative Interests

PSD3, Open Finance (FIDA), Instant Payments Regulation (IPR), AMLR/AMLA. Some proposals include A. Levelling the playing field Harmonisation across member states of technical interfaces around availability, quality and performance - moving away from lowest common denominator application for ASPSPs Access to data: different interpretations of what data should be made available via APIs eg. credit accounts not being classified as payment accounts in some Member States Poor user journey (UX) for open banking transactions compared to other online banking channels Challenges around different applications of SCA, adding friction to open banking payments Lack of transparency/information provided by ASPSPs on payment transaction data and transaction history length B. Definition and Scope Broadening the scope of payment accounts to include savings, investments, mortgages and pensions (moving towards open finance) Scope and definition of AIS and PIS need to be revised so as not to subject to the same AML requirements as other payment institutions C. Supervision and enforcement Lack of monitoring and supervision of APIs from existing standards bodies Unsatisfactory application and enforcement of PSD2 rules at the local level by National Competent Authorities D. Cross border payments Ensuring that cross border payments are as seamless as domestic payments across SEPA area Address issues around IBAN discrimination, which is still prevalent in the market E. Creating an environment which stimulates innovation Commercialisation of APIs / incentives for ASPSPs Proposing that future reforms be enshrined in regulation rather than a directive to minimise fragmentation across Member States II. OPEN FINANCE CONSULTATION (FIDA) A. Scope and Data Access Broadening the scope of data accessible by TPPs (beyond payment accounts to include all other financial data) Giving data holders the ability to explicitly consent to TPPs sharing their data with any other third party firms Ability for third parties to action/ make use of their data beyond access (eg payment initiation, moving funds between accounts) B. Premium APIs/ compensation by third parties for data access Mandating a core set of data beyond payment accounts but with the ability to charge premium / enhanced data provisions Balanced approach to compensation for access to data by third parties C. Apply learnings from PSD2 to open finance Level playing field when it comes to performance and quality of APIs made available by data holders when compared to direct bank channels Consistent approach by NCAs around scope and definition D. Licensing and authorisation AISP licenses should extend to cover access other types of financial data (beyond PSD2) E. Open Finance Framework Propose a mix of regulatory and commercial incentives for data access in open finance Contractual schemes should be explored, which would allow for standardisation of contracts between TPPs and financial institutions F. Standardisation of APIs Mandatory use of standardised formats for APIs to promote market adoption - these should not be prescriptive but provide a framework for quality assurance Industry stakeholders together with European standards bodies should develop a common API standards for open finance Regulatory intervention is necessary to move to towards API standards for open finance

Interests Represented

Promotes their own interests or the collective interests of their members

Member Of

Open Finance Association European Third Party Providers Association (ETPPA)