ERU, Alm.del - 2021-22 - Bilag 340: Orientering om høringssvar vedr. revision af andet betalingstjenestedirektiv (PSD2) og open finance, fra erhvervsministeren

Erhvervsudvalget 2021-22
ERU Alm.del Bilag 340
Offentligt

Public consultation on the review of the

revised payment services Directive (PSD2) and

on open finance

Fields marked with * are mandatory.

Introduction

This consultation is available in all European Union official languages.

Please use the language selector at the top of this page to choose your language for this consultation.

Purpose and structure of the consultation

The Commission is launching this public consultation to gather evidence for the PSD2 review and to inform its work on

open finance. It targets the public, and no in-depth knowledge of PSD2 or open finance is required. It is available in all

official EU languages.

As well as this public consultation, two targeted consultations will be launched, one

targeted consultation on the review

of PSD2

and the

targeted consultation on the open finance framework

. These consultations will have more detailed

questions that require specific knowledge of payment services, the PSD2, and data sharing in the financial sector.

These targeted consultations are only available in English.

We invite you to respond to

this public consultation

if you have little knowledge about the payments industry and the relevant laws

one or both of the

targeted consultations

if you are a professional stakeholder in the payments industry, e.g.

you are a payment institution employee, represent a financial institution members’ association, or are

knowledgeable about payments

The results of all the consultations will inform the PSD2 review and open finance policy. The results may also serve as

input for impact assessments accompanying any possible legislative proposals revising the PSD2 or putting in place an

open finance framework.

In addition to answering to the questions raised in this online survey, you can add any useful documents and

/or data (this can be done at the end of this questionnaire).

Please give concrete examples in your answers when possible. Where appropriate, please make specific

operational suggestions to the questions raised. This will support the review process.

ERU, Alm.del - 2021-22 - Bilag 340: Orientering om høringssvar vedr. revision af andet betalingstjenestedirektiv (PSD2) og open finance, fra erhvervsministeren

Background

The

revised Payment Services Directive (Directive 2015/2366/EC)

is the basis for payment rules in the EU. The

first

Payment Services Directive

, adopted in 2007, was revised to modernise rules due to increased digitalisation of

payments and the emergence of new payment services providers and types of payment services. The Directive

became applicable in January 2018, except for some rules on strong customer authentication (SCA) and access to

payment accounts, which apply since September 2019.

PSD2 includes rules to

make it easier and safer to use online payment services

better protect payment services users against fraud, abuse, and payment problems

promote innovative payment services

strengthen the rights of payment services users

PSD2 sets out the conditions under which digital payments are to be executed. For example

how long it should take for an account to be credited (execution time)

whether there are fees associated with the transaction

safety measures to be applied to ensure the security of the payment

the liability regime in the event of unauthorised access (fraud), i.e. who is responsible

how to file complaints

PSD2 focuses on digital payments, e.g. non-cash payments using payment instruments such as cards, credit transfers,

direct debits, etc. that can be made in person or via online banking, e.g. via a mobile phone.

Since the adoption of PSD2, the payments market has continued to evolve with new players entering the market, more

advanced payments technologies (such as contactless) emerging, and payments needs changing. These market

changes warrant an in-depth analysis.

The review aims to assess the effectiveness, efficiency, costs and benefits, coherence and the EU added value of the

Directive. It will determine if the PSD2 objectives have been achieved or if changes are needed (and if so, the type and

scope of changes). Any forward-looking aspects will also consider the Commission’s ongoing work on the open finance

framework.

The review will have two dimensions. It will be backward-looking (evaluating the application and impact of the Directive)

and forward-looking (assessing the need for possible legislative amendments ensuring that EU retail payment rules

remain fit for purpose and future-proof).

As regards open finance, the revised PSD2 opened up access to customers’ payment accounts data, enabling third-

party information and financial service providers to reuse this data with the customer’s agreement. The general purpose

of this data reuse was to offer competing financial services or information services, such as comparison tools and data

aggregation across several providers. Thus, the PSD2 effectively laid the ground for ‘open banking’, or the principle of

ERU, Alm.del - 2021-22 - Bilag 340: Orientering om høringssvar vedr. revision af andet betalingstjenestedirektiv (PSD2) og open finance, fra erhvervsministeren

third-party access to customer data in the area of banking products and services. Open finance as a concept is broader

and goes beyond the scope of payments account data in the revised PSD2, as it could cover a range of financial

services, such as investment in securities, pensions and insurance.

In 2020, the Commission set data-driven finance as one of the priorities in its

digital finance strategy

and announced an

open finance framework legislative proposal. As reiterated in the

capital markets union (CMU) Communication of

November 2021

, the Commission is now accelerating this work as an integral part of the European financial data

space. In the broader framework of the

data strategy for Europe

, the objective is to make the most of the data economy

for EU capital markets, consumers and businesses. Building on the PSD2, this will ensure that more data are available

for innovative financial services. It will also give consumers more choice and help them find products that best fit their

investment preferences (including sustainable products), while continuing to give them control of their data, including

who can access it. This should directly contribute to increasing retail investment.

Please note:

In order to ensure a fair and transparent consultation process

only responses received through our

online questionnaire will be taken into account

and included in the report summarising the responses. Should you

have a problem completing this questionnaire or if you require particular assistance, please contact

fisma-psd2-

[email protected]

More information on

this consultation

the consultation document

the related call for evidence on the review of PSD2

the related targeted consultation on the review of PSD2

the related call for evidence on the open finance framework

the related targeted consultation on the open finance framework

payments services

the protection of personal data regime for this consultation

About you

Language

of my contribution

Bulgarian

Croatian

Czech

Danish

Dutch

English

ERU, Alm.del - 2021-22 - Bilag 340: Orientering om høringssvar vedr. revision af andet betalingstjenestedirektiv (PSD2) og open finance, fra erhvervsministeren

Estonian

Finnish

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Portuguese

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am giving my contribution as

Academic/research institution

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Company/business organisation

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Public authority

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Other

First

name

ERU, Alm.del - 2021-22 - Bilag 340: Orientering om høringssvar vedr. revision af andet betalingstjenestedirektiv (PSD2) og open finance, fra erhvervsministeren

Surname

(this won't be published)

Scope

International

Local

National

Regional

Level

of governance

Local Authority

Local Agency

Level

of governance

Parliament

Authority

Agency

Organisation

name

255 character(s) maximum

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size

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Transparency register number

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Check if your organisation is on the

transparency register

. It's a voluntary database for organisations seeking to

influence EU decision-making.

ERU, Alm.del - 2021-22 - Bilag 340: Orientering om høringssvar vedr. revision af andet betalingstjenestedirektiv (PSD2) og open finance, fra erhvervsministeren

Country

of origin

Djibouti

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Republic

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Miquelon

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and the

Grenadines

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Please add your country of origin, or that of your organisation.

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Germany

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Greece

ERU, Alm.del - 2021-22 - Bilag 340: Orientering om høringssvar vedr. revision af andet betalingstjenestedirektiv (PSD2) og open finance, fra erhvervsministeren

Bhutan

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Eustatius and

Saba

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Herzegovina

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Ocean Territory

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Tobago

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Caicos Islands

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Emirates

United Kingdom

ERU, Alm.del - 2021-22 - Bilag 340: Orientering om høringssvar vedr. revision af andet betalingstjenestedirektiv (PSD2) og open finance, fra erhvervsministeren

Clipperton

Cocos (Keeling)

Islands

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Croatia

Cuba

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Minor Outlying

Islands

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Republic of the

Congo

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Field

Lesotho

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Nevis

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of activity or sector (if applicable)

Accounting

Auditing

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Credit rating agencies

Insurance

Pension provision

Investment management (e.g. hedge funds, private equity funds, venture

capital funds, money market funds, securities)

Market infrastructure operation (e.g. CCPs, CSDs, Stock exchanges)

Social entrepreneurship

Other

ERU, Alm.del - 2021-22 - Bilag 340: Orientering om høringssvar vedr. revision af andet betalingstjenestedirektiv (PSD2) og open finance, fra erhvervsministeren

Not applicable

Please

specify your activity field(s) or sector(s)

The Commission will publish all contributions to this public consultation. You can choose whether you

would prefer to have your details published or to remain anonymous when your contribution is published.

r the purpose of transparency, the type of respondent (for example, ‘business association,

‘consumer association’, ‘EU citizen’) country of origin, organisation name and size, and its

transparency register number, are always published. Your e-mail address will never be published.

Opt in to select the privacy option that best suits you. Privacy options default based on the type of

respondent selected

Contribution

publication privacy settings

The Commission will publish the responses to this public consultation. You can choose whether you would like

your details to be made public or to remain anonymous.

Anonymous

The type of respondent that you responded to this consultation as, your

country of origin and your contribution will be published as received. Your

name will not be published. Please do not include any personal data in the

contribution itself.

Public

Your name, the type of respondent that you responded to this consultation as,

your country of origin and your contribution will be published.

Contribution

publication privacy settings

The Commission will publish the responses to this public consultation. You can choose whether you would like

your details to be made public or to remain anonymous.

Anonymous

Only organisation details are published: The type of respondent that you

responded to this consultation as, the name of the organisation on whose

behalf you reply as well as its transparency number, its size, its country of

origin and your contribution will be published as received. Your name will not

be published. Please do not include any personal data in the contribution itself

if you want to remain anonymous.

ERU, Alm.del - 2021-22 - Bilag 340: Orientering om høringssvar vedr. revision af andet betalingstjenestedirektiv (PSD2) og open finance, fra erhvervsministeren

Public

Organisation details and respondent details are published: The type of

respondent that you responded to this consultation as, the name of the

organisation on whose behalf you reply as well as its transparency number, its

size, its country of origin and your contribution will be published. Your name

will also be published.

I agree with the

personal data protection provisions

Payment methods

Question

How

you

usually

pay

for

goods

and

services?

For each payment method, please indicate how often you use it

a) In a physical shop:

Don't

(preferred

option)

(sometimes)

(never)

know -

opinion -

Not

applicable

Cash

Payment card (debit or credit)

Digital wallet on mobile phone

Other payment solutions

Please specify to what other payment solution(s) you refer in your answer to

question 1 b):

750 character(s) maximum

including spaces and line breaks, i.e. stricter than the MS Word characters counting method.

Question 2. The Payment Services Directive aims to promote innovative

internet-based

and

mobile

payment

services.

Do you think that the payments market is innovative enough?

Yes

Don’t know / no opinion / not applicable

Question 2.1 Please explain why you don't think the payments market is

innovative enough:

1000 character(s) maximum

including spaces and line breaks, i.e. stricter than the MS Word characters counting method.

ERU, Alm.del - 2021-22 - Bilag 340: Orientering om høringssvar vedr. revision af andet betalingstjenestedirektiv (PSD2) og open finance, fra erhvervsministeren

In recent years,

new payment service providers

have entered the market. Many are not banks, and they include big

tech companies (i.e. large online platforms offering search engines, social networking services and more).

Question 3.1 Do you believe that you have a larger choice of payment

services than you did 5 years ago?

Yes

No, I have the same choice as before

No, I have less choice

Don’t know / no opinion / not applicable

Question 3.2 What do you think about new companies, including big tech

companies, entering the payments market?

1000 character(s) maximum

including spaces and line breaks, i.e. stricter than the MS Word characters counting method.

To use these services, payment service providers need access to your payment account(s) data, which requires your

consent. There are two kinds of providers

Account information services providers (AISP):

these access data from your online accessible payment

account(s) and consolidate these data to, for example, help you manage your finances

Payment initiation services providers (PISP):

these provide an online service that accesses your payment

account to transfer funds on your behalf with your consent and authentication. For example, you could have

payment accounts from different banks together in a PISP app on your phone and transfer funds from any of

those payment accounts directly from the app

AISPs and PISPs do not actually handle your funds. Once they have your consent, AISPs get access to your

transaction history, and PISPs facilitate the payment, but they never come into possession of your funds.

Question 3.3 Do you use AISPs and/or PISPs?

I only use AISP(s)

I only use PISP(s)

ERU, Alm.del - 2021-22 - Bilag 340: Orientering om høringssvar vedr. revision af andet betalingstjenestedirektiv (PSD2) og open finance, fra erhvervsministeren

I use both AISPs and PISPs

I don't use any of them

Don’t know / no opinion / not applicable

Question 3.4 If you do not use AISPs and/or PISPs, what are your reasons for

this?

Please select as many answers as you like

I don’t need their services

I don’t trust those providers

I don’t want to share my data with other companies besides my own bank

I did not know these providers exist

Other

Please specify to what other reason(s) you refer in your answer to question

3.4:

750 character(s) maximum

including spaces and line breaks, i.e. stricter than the MS Word characters counting method.

Digital payments

Question 4. Do you make digital payments?

Yes

Don’t know / no opinion / not applicable

An important objective of the Payment Services Directive was to make digital payments (non-cash payments using

electronic payment instruments, e.g. payment cards, mobile phones, etc.) and online banking safer and easier for

consumers.

ERU, Alm.del - 2021-22 - Bilag 340: Orientering om høringssvar vedr. revision af andet betalingstjenestedirektiv (PSD2) og open finance, fra erhvervsministeren

Question 4.1 Based on your experience with digital payments over the last

5 years, please indicate to what extent you agree with the following

statements:

Don't

(strongly

agree)

(somewhat

agree)

(neutral)

(somewhat

disagree)

(strongly

disagree)

know -

opinion -

Not

applicable

Making

digital

payments

has become

easier

It has

become

easier to

make digital

payments to

other EU

countries (e.

g. when

buying from

an online

shop in

another EU

country)

ERU, Alm.del - 2021-22 - Bilag 340: Orientering om høringssvar vedr. revision af andet betalingstjenestedirektiv (PSD2) og open finance, fra erhvervsministeren

It has

become

easier to

make digital

payments to

non-EU

countries (e.

g. when

buying from

an online

shop in a

non-EU

country)

It has

become

easier to

transfer

money to

other EU

countries

It has

become

easier to

transfer

money to

non-EU

countries

ERU, Alm.del - 2021-22 - Bilag 340: Orientering om høringssvar vedr. revision af andet betalingstjenestedirektiv (PSD2) og open finance, fra erhvervsministeren

The Payment Services Directive includes measures to protect consumers. Some examples are described below

(please note that the below is not an exhaustive list)

Transparency: before and after transactions have been executed, payment service providers must inform users

about all fees payable, when the transaction will be completed, etc.

Rights and obligations: for some unauthorised payment transactions, the Directive has limited the liability of the

payer, for example, when a payment card is lost

Fraud prevention: PSD2 introduced strong customer authentication (SCA, see explanation below) for making

payment transactions or giving access to payment accounts

The following questions ask your opinion on consumer protection and the Payment Services Directive.

ERU, Alm.del - 2021-22 - Bilag 340: Orientering om høringssvar vedr. revision af andet betalingstjenestedirektiv (PSD2) og open finance, fra erhvervsministeren

Question 4.2 Please indicate to what extent you agree with the following

statements about information and fees:

Don't

(strongly

agree)

(somewhat

agree)

(neutral)

(somewhat

disagree)

(strongly

disagree)

know -

opinion -

Not

applicable

Before

paying

(either

online or in a

physical

shop), I

know if I will

have to pay

a fee in

addition to

the price of

the product

(s) or service

(s)

purchased

The cost of

any fees is

always clear

ERU, Alm.del - 2021-22 - Bilag 340: Orientering om høringssvar vedr. revision af andet betalingstjenestedirektiv (PSD2) og open finance, fra erhvervsministeren

If a payment

includes a

currency

conversion

(e.g. from

euro to

Swedish

Krona), it is

always clear

what

exchange

rate will be

applied

When

charged with

fees for ATM

cash

withdrawals,

it is always

clear what

these fees

are

ERU, Alm.del - 2021-22 - Bilag 340: Orientering om høringssvar vedr. revision af andet betalingstjenestedirektiv (PSD2) og open finance, fra erhvervsministeren

When

withdrawing

cash abroad

at an ATM in

another

currency, it

is always

clear what

exchange

rate will be

applied

The

information I

receive

before I

make a

payment is

sufficient

ERU, Alm.del - 2021-22 - Bilag 340: Orientering om høringssvar vedr. revision af andet betalingstjenestedirektiv (PSD2) og open finance, fra erhvervsministeren

Question 4.2.1 If you find that the information provided to you during a

payment transaction or cash withdrawal is not always clear, please explain

what is not clear?

1000 character(s) maximum

including spaces and line breaks, i.e. stricter than the MS Word characters counting method.

Question 4.2.2 Do you require additional information before making a

payment?

Yes

Don’t know / no opinion / not applicable

Please explain what additional information you need before making a

payment:

750 character(s) maximum

including spaces and line breaks, i.e. stricter than the MS Word characters counting method.

To make payment transactions more secure and prevent fraud further, the Payment Services Directive introduced

strong customer authentication (SCA or ‘2-factor authentication’). This requires authentication through a combination of

two of the following three factors: ‘something I possess’ (e.g. card, mobile phone), ‘something I know’ (e.g. PIN), or

‘something I am’ (e.g. fingerprints).

Making a payment, either in a physical shop or online, usually involves SCA (except in certain circumstances, e.g. low-

value contactless payments). SCA can be done using a mobile phone or through other means, such as card reader or

a code-generating device.

Question 4.3 What is your opinion about confirming your payment with SCA?

a) When buying something in a physical shop:

It is easy, and I have no problem with it

It is cumbersome, but I accept it because it protects me against fraudsters

It is cumbersome, and I do not see the point of it

ERU, Alm.del - 2021-22 - Bilag 340: Orientering om høringssvar vedr. revision af andet betalingstjenestedirektiv (PSD2) og open finance, fra erhvervsministeren

Other

Don’t know / no opinion / not applicable

Please specify to what is your opinion about confirming your payment with

SCA when buying something in a physical shop:

750 character(s) maximum

including spaces and line breaks, i.e. stricter than the MS Word characters counting method.

b) When buying something online:

It is easy, and I have no problem with it

It is cumbersome, but I accept it because it protects me against fraudsters

It is cumbersome, and I do not see the point of it

Other

Don’t know / no opinion / not applicable

Please specify to what is your opinion about confirming your payment with

SCA when buying something online:

750 character(s) maximum

including spaces and line breaks, i.e. stricter than the MS Word characters counting method.

Payment service providers are required to implement SCA and can decide how to implement it. They usually enable

SCA via a mobile phone app and/or another specific device.

Question 4.3.1 Besides payments made on mobile phones, do you think

payment service providers should be required to offer SCA solutions other

than through mobile phones?

Yes

Don’t know / no opinion / not applicable

ERU, Alm.del - 2021-22 - Bilag 340: Orientering om høringssvar vedr. revision af andet betalingstjenestedirektiv (PSD2) og open finance, fra erhvervsministeren

Question 4.3.2 Do you believe payment service providers should put in place

more security measures?

Yes

Don’t know / no opinion / not applicable

Please explain your answer to question 4.3.2 and include any suggestions:

1000 character(s) maximum

including spaces and line breaks, i.e. stricter than the MS Word characters counting method.

Since the COVID-19 pandemic, the number of contactless payments has increased significantly. The maximum amount

for contactless payment transactions without SCA was increased to EUR 50 by payment service providers in most

countries.

Question 4.4.1 What do you think about the maximum amount for a

contactless

payment

(without

SCA)?

If the euro is not the main currency in your country of residence, please

convert EUR 50 to your local currency and select an answer:

The EUR 50 limit should remain

The limit should be lower than EUR 50

The limit should be higher than EUR 50

I should be able to set my own limit

Other

Don’t know / no opinion / not applicable

Please specify to what other view(s) you have on the maximum amount for a

contactless payment (without SCA):

750 character(s) maximum

including spaces and line breaks, i.e. stricter than the MS Word characters counting method.

ERU, Alm.del - 2021-22 - Bilag 340: Orientering om høringssvar vedr. revision af andet betalingstjenestedirektiv (PSD2) og open finance, fra erhvervsministeren

There is also a limit to the cumulative value of contactless payments, which differ by country. For example, in Germany,

one must enter a PIN every three to five transactions or when a total of EUR 150 has been spent. In Czechia, a PIN is

required for every third consecutive transaction.

Question 4.4.2 What is your opinion about this cumulative limit for contactless payments (without SCA)?

Please

give

one

answer

for

the

value

limit

and

one

for

the

payments

limit.

If the euro is not the main currency in your country of residence, please convert EUR 50 to your local currency

and select an answer for ‘Value in euro’:

a) Value in euro:

The limit should be lower than EUR 150

The limit should be higher than EUR 150

I should be able to set my own limit (including EUR 0)

Other

Please specify to what other view(s) you have on the value limit for

contactless payments (without SCA):

750 character(s) maximum

including spaces and line breaks, i.e. stricter than the MS Word characters counting method.

b) Number of consecutive payments:

This should be less than five consecutive payments

This should be more than five consecutive payments

I should be able to set my own limit (including zero payments)

Other

Please specify to what other view(s) you have on the payments limit for

contactless payments (without SCA):

750 character(s) maximum

ERU, Alm.del - 2021-22 - Bilag 340: Orientering om høringssvar vedr. revision af andet betalingstjenestedirektiv (PSD2) og open finance, fra erhvervsministeren

including spaces and line breaks, i.e. stricter than the MS Word characters counting method.

Blocking funds

For payments by card, funds can be blocked on your account if the exact final amount unknown at the time of payment.

For example, when you are at an unmanned petrol station, you may have to agree to a certain amount of funds to be

blocked before you fill up your tank. The blocked amount will then be corrected, and the exact final payment will be

processed afterwards.

Question 4.5 Should there be a limit on the amount that can be blocked?

Yes

No, no limit is needed

Other

Don’t know / no opinion / not applicable

Question 4.5.1 Please explain what should be the limit on the amount that

can be blocked:

750 character(s) maximum

including spaces and line breaks, i.e. stricter than the MS Word characters counting method.

Question 4.5.1 Please specify what you mean by "other" in your answer to

question 4.5:

750 character(s) maximum

including spaces and line breaks, i.e. stricter than the MS Word characters counting method.

Fraud

ERU, Alm.del - 2021-22 - Bilag 340: Orientering om høringssvar vedr. revision af andet betalingstjenestedirektiv (PSD2) og open finance, fra erhvervsministeren

Question 4.6 As a consumer, have you been a victim of payment fraud

recently?

Yes

Don’t know / no opinion / not applicable

Question 4.6.1 Please provide details on the payment fraud you have been a

victim of:

2000 character(s) maximum

including spaces and line breaks, i.e. stricter than the MS Word characters counting method.

Question 4.6.2 If you were victim of a fraud did you ask your payment service

provider for a refund?

Yes, and I received a full refund

Yes, but I only received a partial refund

Yes, but I did not receive any refund

Yes, but I requested a refund from another party

No, I did not request a refund

Don’t know / no opinion / not applicable

Question 4.6.3 Were you satisfied with the refund process (requesting the

refund, communication with your payment service provider, length of the

process, etc.)?

1000 character(s) maximum

including spaces and line breaks, i.e. stricter than the MS Word characters counting method.

ERU, Alm.del - 2021-22 - Bilag 340: Orientering om høringssvar vedr. revision af andet betalingstjenestedirektiv (PSD2) og open finance, fra erhvervsministeren

Question 4.7 Please indicate to what extent you agree with the following

statements about protection and security provided when making digital

payments:

Don't

(strongly

agree)

(somewhat

agree)

(neutral)

(somewhat

disagree)

(strongly

disagree)

know -

opinion -

Not

applicable

Making digital

payments has

become more

secure

My payments

data is

adequately

protected

Strong

customer

authentication

has helped

make digital

payments

safer and

more secure

ERU, Alm.del - 2021-22 - Bilag 340: Orientering om høringssvar vedr. revision af andet betalingstjenestedirektiv (PSD2) og open finance, fra erhvervsministeren

For digital

payments,

convenience

and speed

are more

important

than security

ERU, Alm.del - 2021-22 - Bilag 340: Orientering om høringssvar vedr. revision af andet betalingstjenestedirektiv (PSD2) og open finance, fra erhvervsministeren

Question 4.7.1 Please explain your answers and include any proposals you

may have that further protect digital payments:

2000 character(s) maximum

including spaces and line breaks, i.e. stricter than the MS Word characters counting method.

Considering your responses to the questions above and that the payments market has many new players and

technologies (including big tech companies and mobile phone payments):

Question 4.8.1 Do you have specific concerns about the payments market

and recent market developments? For instance are there (new) risks that

require special attention?

Yes

Don’t know / no opinion / not applicable

Please explain your answer to question 4.8.1:

2000 character(s) maximum

including spaces and line breaks, i.e. stricter than the MS Word characters counting method.

Question 4.8.2 What is your opinion about the level of regulation of the

payments market? Is it sufficient or is there too much regulation? Please

explain:

2000 character(s) maximum

including spaces and line breaks, i.e. stricter than the MS Word characters counting method.

ERU, Alm.del - 2021-22 - Bilag 340: Orientering om høringssvar vedr. revision af andet betalingstjenestedirektiv (PSD2) og open finance, fra erhvervsministeren

Open finance

Open finance refers to a customer allowing their data to be shared or re-used by financial institutions and other third-

party service providers to access a wider range of innovative services. It could cover different sets of data (business-to-

business and business-to-consumer data) across a range of financial services (e.g. banking, insurance, investment,

pensions). Consumers would be able to grant trusted third-party service providers access to their data, held by financial

institutions or other service providers, in a safe and secure way until they decide to revoke their permission. As a result,

consumers would have access to better or new services from these third-party service providers, including better-

targeted financial advice, tools to manage their finances, and additional financial services. While the revised Payment

Services Directive includes rules on such access for payment accounts (see previous sections of this consultation), no

framework currently exists for other financial products.

Question 5. Would you be willing to share the following types of data held by

your financial service provider (e.g. bank, insurance company, investment

company) with other financial or third-party service providers to get access

to new services (e.g. comparing offers, switching providers, financial

services tailored to your situation and needs)?

Don't

know -

opinion -

Not

applicable

Savings account data

Mortgage loan data

Consumer credit data

Securities account data

Pension data

Insurance data

Yes

Please explain your answer to question 5:

750 character(s) maximum

including spaces and line breaks, i.e. stricter than the MS Word characters counting method.

ERU, Alm.del - 2021-22 - Bilag 340: Orientering om høringssvar vedr. revision af andet betalingstjenestedirektiv (PSD2) og open finance, fra erhvervsministeren

Question 6. Should financial service providers holding your data be obliged

to share them with other financial or third-party service providers, provided

that you have given your consent?

Yes

Don’t know / no opinion / not applicable

Question 7. Do you think there are security and/or privacy risks in giving

other service providers access to your data?

Yes

Don’t know / no opinion / not applicable

Please explain your answer to question 7:

750 character(s) maximum

including spaces and line breaks, i.e. stricter than the MS Word characters counting method.

Question 8. Do you think financial service providers that hold your data

always ask for your consent before sharing those data with other financial or

third-party service providers?

Yes

Don’t know / no opinion / not applicable

Question 9. If shared with another financial or third-party service provider, do

you think these data are used exclusively for the purposes for which you

have agreed?

Yes

Don’t know / no opinion / not applicable

ERU, Alm.del - 2021-22 - Bilag 340: Orientering om høringssvar vedr. revision af andet betalingstjenestedirektiv (PSD2) og open finance, fra erhvervsministeren

Question 9.1 If not, how could this best be ensured?

750 character(s) maximum

including spaces and line breaks, i.e. stricter than the MS Word characters counting method.

Exchanging data between different service providers could be made more secure by putting in place a dedicated

technical infrastructure for that purpose (e.g. a secure application programming interface).

Question 10. If service providers holding data put in place such

infrastructure, do you think they should be able to charge a fee to other

service providers who access data using this infrastructure?

Yes

Don’t know / no opinion / not applicable

Please explain your answer to question 10:

750 character(s) maximum

including spaces and line breaks, i.e. stricter than the MS Word characters counting method.

Additional information

Should you wish to provide additional information (e.g. a position paper,

report) or raise specific points not covered by the questionnaire, you can

upload your additional document(s) below.

Please make sure you do not

include any personal data in the file you upload if you want to remain

anonymous

ERU, Alm.del - 2021-22 - Bilag 340: Orientering om høringssvar vedr. revision af andet betalingstjenestedirektiv (PSD2) og open finance, fra erhvervsministeren

The maximum file size is 1 MB.

You can upload several files.

Only files of the type pdf,txt,doc,docx,odt,rtf are allowed