The EMA has responded to HM Treasury’s consultation on the implementation of the EU Payment Accounts Directive (PAD).The EMA supports the aims of the Directive: to improve transparency around fees, facilitate switching between accounts, and ensure access to basic bank accounts. We also support HMT’s proposed approach – to introduce as little disruption as possible to UK firms by aligning the implementing rules with the UK’s existing system. However, the scope of the directive in relation to non-bank payment accounts lacks clarity. As a result it could bring a wide variety of e-money accounts into the scope unnecessarily, such as prepaid cards or online wallets, which are generally considerably different from bank current accounts in terms of consumer usage and purpose. This would lead to significant disruption and cost for UK e-money issuers.
The law implementing PAD is due to be adopted and published by the UK government by 18 September 2016, with certain elements of the requirements applying by early 2018.Download the EMA response (PDF)