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Germany PSD II – Application period started!

Germany PSD II – Application period started!

Published

Jan 12 2018

Written By

As co-head of the global Finance & Financial Regulation Practice Groups and head of the German Finance & Financial Regulation Practice Group, I advise on national and international finance and capital markets law as well as on commercial and corporate law. I am also a member of the international steering group of our Financial Services Sector Group.

Johannes Wirtz, LL.M. (London)

Partner
Germany

As partner in our Finance & Financial Regulation Group in Frankfurt, I advise our national and international clients on banking regulatory issues and finance law.

As of 13 January 2018, all Account Information Service Providers (read more about AISP in German) and Payment Initiation Service Providers (read more about PISP in German), so called “Third Party Payment Service Providers” (TPPSP) are subject to a statutory registration or authorization requirement due to the newly implemented Payment Services Supervision Act (Zahlungsdiensteaufsichtsgesetz – ZAG; read more about the ZAG in German).

All service providers conducting account information service or payment initiation service after 13 January 2018 are required to hold a registration or authorization with the German financial supervision authority BaFin. Registrations or authorization applications for Account Information Service Providers and Payment Initiation Service Providers shall be filed within a period of three months. We recommend to notify BaFin about the intended application in due course.

BaFin is of the opinion that also Account Information Service Providers and Payment Initiation Service Providers which operated before 12 January 2016 have to comply with the registration / authorization requirement within said three month period in order to be able to continue their services. An exception to await the regulatory technical standards on authentication and communication (RTS) become applicable (approx. September 2019) has not legal bases in Germany.

In case you need any assistance with your application at BaFin, let us know!