Europaudvalget 2020-21
EUU Alm.del Bilag 658
Offentligt
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s
Mairead McGuinness
Commissioner for Financial Services, Financial Stability and the Capital
Markets Union
European Commission
MINISTER FOR INDUSTRY,
BUSINESS AND FINANCIAL
AFFAIRS
MINISTRY OF INDUSTRY,
Dear Commissioner Mairead McGuinness,
Thank you for the opportunity to respond to this consultation on instant
payments, which is an area that provides and enables innovative solutions
across all sectors. The Danish government supports efforts to ensure the
continued development of the European payments market, and we welcome
the Commissions work on the retail payments strategy.
The Danish government welcomes the Commission initiative to explore
ways to further reap the benefits stemming from instant retail payments as
they provide benefits in terms of certainty for completion of the transaction
and convenience for the payee from the immediate receipt of funds.
In our view, it is very important that these possible benefits are based on a
strong level of consumer protection and therefore, this should be a pivotal
aspect going forward. Current established and well-functioning payment
solutions, e.g. card payments, have strong built-in consumer protection el-
ements, such as liability and charge-back regimes. We find it important to
ensure that this high level of consumer protection is also in place for new
payment solutions, including solutions built on instant credit transfers.
Along this line a general issue and a limiting factor on the uptake of such
solutions are that services based on credit transfers (such as payment initi-
ation services) today does not entail the same degree of consumer protec-
tion as the aforementioned example of card payments.
In Denmark, the widespread adoption of electronic payments has to a large
extent been based on strong consumer confidence in the available payment
solutions. Thus, strong consumer protection in new solutions will be an
efficient measure in promoting market-driven uptake of new solutions.
Furthermore, an emphasis should also be placed on the general principle of
technology neutral regulation as it enforces user friendly and price compet-
itive solutions. Experiences from Denmark and the other Nordic countries
show that once the relevant infrastructure is in place, the market is able to
develop new solutions based on instant payments that enjoy wide-spread
BUSINESS AND FINANCIAL
AFFAIRS
Slotsholmsgade 10-12
1216 Copenhagen K
Denmark
Tlf.
+45 33 92 33 50
Fax.
+45 33 12 37 78
CVR-nr. 10092485
EAN nr. 5798000026001
[email protected]
www.em.dk
 EUU, Alm.del - 2020-21 - Bilag 658: Notat samt høringssvar vedr. Kommissionens offentlige høring om instant payments
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uptake among consumers and merchants, when such solutions satisfies a
demand in the market.
This is the case for mobile payment solutions like MobilePay (Denmark),
Swish (Sweden) and Vipps (Norway) and should equally be a key aspect
when introducing new initiatives. As such, well-functioning instant pay-
ments systems and widely used payment services built on this infrastruc-
ture are in place outside the euro-area. This should be given due consider-
ation as well when considering any initiative on interoperability between
instant payment systems.
In order to reach the goal of furthering new innovative instant payments
solutions, we should not, as a starting point, prescribe specific products or
solutions to the market. Requirements that force or place an emphasis on
specific solutions on the market should only be introduced after rigorous
analysis that demonstrate that benefits clearly outweighs costs.
Moreover, we underline the importance of proportionality when applying
requirements on a euro-based payments scheme outside the euro-area. Cur-
rently, nine different currencies are in use within the EU, and requirements
such as mandatory instant euro payments provided by PSP’s would poten-
tially provide little added value in Member States outside the euro-area.
Furthermore, with a more widespread rollout of instant payments into retail
payments, we need to ensure that the fundamental prerequisites are in
place, not only in terms of consumer protection, but also of more general
fraud prevention and management of anti-money laundering. It is vital that
these risks are thoroughly analyzed before adoption of these solutions.
The Danish government remains committed to your work on the retail pay-
ments strategy and the new initiatives it will introduce. Bolstering our pay-
ment solutions with innovative advantages will benefit a wide area of user-
segments and the continued development of the European payment market.
Yours sincerely,
Simon Kollerup