Given the sea change of payment services directive 2015/2366 (“PSD2”), one might expect the prospect of the proposed PSD3 and PSR to have psps groaning at the thought of yet more root and branch reg change projects. However, whilst the proposals are certainly wide-ranging and will require psps to make further changes, this latest chapter in the ongoing saga of payments regulation is slightly more “evolution” than the “revolution” of its predecessor.
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