Payments: steady, safe, sovereign

The emergence of EU-wide cross-border instant payment solutions

European policymakers are particularly keen on ensuring that future developments in the field of instant payments lead to the emergence of EU-wide cross-border instant payment solution(s) in euros, due to fears that foreign governments could hold leverage over the EU if global companies from non-European countries, as service providers with global market power, will not necessarily act in the best interest of European stakeholders.

Payment Accounts Directive

It is very easy for consumers to change accounts due to the account switching services, especially since the implementation of the Payment Account Directive 2014/92, which specifies the requirements for account switching services within the European Union.

Identified Concerns

The PAD has been implemented too late in some member states, and therefore it is too early to make an assessment. In addition, ESBG would like to underline how the PAD was extremely burdensome and costly for operators did not always fulfil customer needs. In addition, customer mobility is a means to an end and should not become an end in itself.

Proposed Solutionsand Actions

It is misleading to compare the IBAN to the case of phone number portability, they are not equivalent nor comparable situations. Policymakers should acknowledge that despite technological development, the IBAN is a very unique mechanism. The IBAN includes, for example, the country code, two check digits, the domestic bank account number, branch identifier. In addition, the length is not the same in every country, it ranges from 16 to 30 digits.

Why PolicymakersShould Act

EU legislators and the European Commission should continue improving the transparency and comparability of fees related to payment accounts that are used for day-to-day payment transactions. They should also ensure that consumers have access to bank accounts with basic features. Policymakers should consider the results of numerous studies which show that a majority of consumers are quite satisfied with their accounts, instead of thinking of addressing non-existent problems linked to market inefficiency and switching.


The Payment Accounts Directive (PAD) was adopted within the European Union in 2014 and is being implemented by EU countries with the main aim of helping the EU internal market foster payment accounts.

The European Commission is currently evaluating the objectives, and a report on the application of this Directive is to be expected soon. However, some may argue that it might be premature to already conduct a full assessment of the Directive’s impact on the market.

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