PSD3 and PSR: the compliance clock is ticking

PSD3

The European Union’s overhaul of its payments framework is edging closer to reality, and payment institutions (PIs) and e-money institutions (EMIs) are being urged not to wait until the deadline looms to act.

According to Vixio, on April 23, 2026, the Council of the EU published what appears to be the near-final text of the third Payment Services Directive (PSD3) and its companion Payment Services Regulation (PSR).

Vixio recently delved deeper into what firms need to know about PSD3 compliance.

Publication in the Official Journal and entry into force are expected in Q3 2026, triggering a 21-month transition period that puts the compliance deadline at around mid-2028.

The distinction between the two instruments matters for planning. PSR applies directly across all member states, while PSD3, as a directive, must be transposed into national law individually, meaning implementation timing could vary by jurisdiction.

The changes are wide-ranging. EMIs will become a licensed sub-category of PIs rather than being governed separately under the second E-Money Directive, which is being repealed. Initial capital requirements are shifting too: money remittance minimums rise from €20,000 to €40,000, and other payment services from €125,000 to €150,000, while EMI requirements fall from €350,000 to €250,000. Firms offering multiple services must now add these minimums together.

Safeguarding rules are also expanding, with two new options added alongside disclosure requirements on how client funds are protected. Payment institutions will no longer be able to hold all safeguarded funds in a single credit institution. Elsewhere, PSPs must verify IBAN and account name matches in real time before executing transfers, and non-bank PSPs gain direct access to central payment systems such as SEPA without needing a sponsor bank.

Liability rules are shifting in payers’ favour too. Under PSD3/PSR, liability for authorised push payment fraud moves to the PSP, unless it can prove gross negligence or fraudulent intent on the victim’s part.

The transition period is not as generous as it sounds. Institutions applying for authorisation for the first time can still do so under PSD2 during the transition window, but reauthorisation under PSD3 will be mandatory regardless. Delays in national implementation could also create complications, including PIs and EMIs being left holding obsolete licences, or facing passporting disputes if their home state hasn’t transposed the directive on time.

The message for the industry is clear, in that final legislation does not mean regulatory certainty. Firms will need to monitor implementation closely across every jurisdiction they operate in.

Read the full Vixio post here. 

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