EUU, Alm.del - 2019-20 - Bilag 828: Notat samt høringssvar vedrørende strategi for detailbetalinger

Europaudvalget 2019-20
EUU Alm.del Bilag 828
Offentligt

Valdis Dombrovskis

Executive Vice-President for An Economy that Works for People and

Commissioner for Financial Services, Financial Stability and Capital

Markets Union

European Commission

Dear Executive Vice-President Valdis Dombrovskis

The Danish government welcomes the opportunity to respond to the

European Commission’s consultation on the coming retail payments

strategy. This consultation touches on many very important issues that

merits further discussion in order to fully harness the potential of a truly

European regulatory framework on payment services for the future. This

letter sums up the Danish governments main focus points in regard to the

coming retail payments strategy. Attached you will find the specific replies

to the consultation document.

First and foremost, we find that a guiding principle should be to further

strengthen consumer protection in the payment services markets.

Established and well-functioning payment solutions, especially that relate

to card payments, have a long list of built-in consumer protection elements,

e.g. liability and charge-back regimes. Strong consumer protection has

been instrumental in ensuring the widespread use of digital payment

solutions in Denmark. When addressing the opportunities and challenges

of novel solutions, we therefore find it paramount to ensure that consumer

protection is maintained and where possible further strengthened. The

marked difference in consumer protection when comparing card payments

and credit transfers should also be taken into consideration.

Besides this, we believe that a guiding principle should be to provide a

robust framework for retail markets in order to develop solutions that cater

to the needs of the European citizens. The market has historically been able

to provide a broad spectrum of payment solutions that cater to the various

needs of the users. We would therefore caution against forcing through a

one-size-fits-all solution on the market.

Keeping the aforementioned guiding principles in mind, while also

acknowledging that the retail payments area is technologically highly

specialised, we furthermore suggest that technology neutral regulation

should be another corner stone in the coming strategy. We should avoid

striving towards innovation through regulation, as this may undermine the

market’s ability to innovate on its own and provide the solutions that the

European citizens demand. Technology neutral regulation is in our view

the best way to support innovation.

Additionally, it is important also to keep in mind that different Member

States are at different stages of digitalisation in their respective retail

payments market. For instance, cash takes up a very different proportion

MINISTER FOR INDUSTRY,

BUSINESS AND FINANCIAL

AFFAIRS

MINISTRY OF INDUSTRY,

BUSINESS AND FINANCIAL

AFFAIRS

Slotsholmsgade 10-12

DK-1216 Copenhagen K

Tlf.

Fax

+45 33 92 33 50

+45 33 12 37 78

CVR-nr. 10 09 24 85

EAN nr. 5798000026001

[email protected]

www.em.dk

EUU, Alm.del - 2019-20 - Bilag 828: Notat samt høringssvar vedrørende strategi for detailbetalinger

of retail payments in Member States, from around 80 pct. in the Eurozone

(with large differences between those Member States) to as little as less

than 20 pct. of transactions in Denmark.

This underlines the fact that when developing our common retail payments

strategy, we should take into account that citizens across the EU have

different preferences for how they like to pay. In many Member States

national card schemes provide efficient, cheap and user-friendly payment

solutions - such as the Dankort in Denmark. When designing the retail

payment strategy attention should be paid to such national solutions.

At the same time, we should continue encouraging payment infrastructure

interoperability to enable strong European brands to engage in competition

that benefit both consumers and businesses. Interoperability between

systems would also have the added value of making it easier to develop

cross border payment solutions.

Finally, it is important to keep in mind that, at the moment, 10 different

currencies are in use within the EU. A European retail payments strategy

should benefit all Member States, regardless of the currency used.

In sum, we believe that the European retail payments strategy should

provide for an adequate technology neutral framework for both existing

and new players on the European retail payments market that allows for

the development of payment solutions that European citizens demand,

while ensuring strengthened consumer protection standards.

As always, I remain at your disposal should you have any questions or

comments.

Yours sincerely,

Simon Kollerup