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Harmonised regulatory frameworks: Payment system operators (PSOs) rely on supervisory and regulatory regimes applicable to credit institutions to ensure their payment systems operate smoothly, a core principle for payment systems. This reliance on supervisory and regulatory regimes makes operating payment systems more efficient and cost-effective. Any lack of harmonisation of technical, operational, financial, governance and risk management (among others) regulatory requirements applicable to bank and non-bank PSPs will have to be addressed by additional verifications and validations by payment system operators, which will increase cost.
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Risk assessment: In order to grant direct access to payment systems for non-banks, we should assess whether new types of participants introduce new risks to the payment system (if any). Their participation should subject to a robust risk assessment by the Commission and by the European system of central banks.
- Non-bank contribution: Today, indirect participants don't bear the investment costs of connecting directly to the payment system, nor the operational, technical and regulatory costs associated with running and maintaining the infrastructure. If direct access is a viable path, non-banks will need to be required to contribute to the maintenance of the payment system.