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EBA follow-up peer review report on authorisation under PSD2
5 December 2025The European Banking Authority (EBA) has published a follow-up peer review report on the authorisation of payment institutions (PIs) and electronic money institutions (EMIs) under the revised Payment Services Directive (PSD2). The review assessed actions taken by 29 national competent authorities (NCAs) following the 2023 report to address recommendations on authorisation processes, implementation of the EBA guidelines on authorisation, governance, AML/CFT controls, and local substance. While most NCAs improved efficiency through clearer guidance, pre-application engagement, and streamlined procedures, authorisation timelines remain highly divergent, ranging from 4-6 months to 27 months in one member state, with a median of 9.5 months (counting from the date of submission of an application). Delays are attributed to incomplete or low-quality applications and the time applicants take to address deficiencies.
While several supervisors have addressed previously identified deficiencies in the implementation of the EBA guidelines, notably on business plan assessments and AML/CFT controls, some gaps remain and in the assessment of local substance, creating risks of regulatory arbitrage. Therefore, despite notable improvements and a general move towards convergence, further efforts are needed. The EBA calls for further convergence to ensure a level playing field and robust supervisory practices across the EU.
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