However the EBF is concerned with the incomplete nature of some of the analysis in the Green Paper, and is convinced that some of the potential measures the paper envisages will not help achieve this diverse (and in some circumstances contradictory) set of objectives. On the contrary, they could be detrimental to their fulfillment and in some cases could directly result in consumer dissatisfaction, confusion and the introduction of inefficiencies.
In addition, the EBF would like to highlight that the Green Paper crucially fails to articulate an overall strategic vision of what the Commission would like to see realised or achieved in the market were the list of potential interventions it contemplates to be progressed. The paper refers to a wide range of specific individual objectives, as noted above, but does not articulate a compelling picture of what all this intervention would actually collectively deliver to the market – particularly in the context of all the parallel regulatory activity at the current time in relation to existing measures such as the implementation of Regulation 260/2012 and the reviews of the PSD, the EMD and Regulation 924/2009.
In the absence of such a strategic vision, the analysis in the Green Paper lacks coherence – and risks promoting a series of unconnected elements of intervention which would therefore carry huge risks of unintended consequences and unwarranted higher costs.
The EBF would therefore suggest the need to define an alternative vision – such as one which would seek to achieve a simplified regulatory structure which embraces technological neutrality and innovation, promotes the development of competitive services that truly meet the needs of end users, and facilitates the true realisation of the digital economy.
Against this background, EBF would particularly highlight the following key observations and policy considerations that need to be kept firmly in mind when reviewing and commenting on the analysis set out by the Commission in the Green Paper:
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If the Commission wishes to facilitate the development of innovative payments in the interests of European consumers and businesses, it should consider how industry innovation and investment, that increase payment security and data protection, can best be facilitated.
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The cost of cash must not be disregarded.
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The focus should be on actual, not assumed, consumer problems.
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Integrity and customer trust are key in payments and must not be compromised. The importance of technological neutrality. The markets for m- and e-payments are in an extremely fast evolutionary phase. Any regulation in these areas needs to recognise this fact and allow space and time for development and innovation and consequently remain technologically neutral.
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Ensuring a level playing field across all payment service providers and payments methods and systems irrespective of their business model, institutional nature and origin is a critical requirement for a competitive market place.
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European payments cannot be considered in isolation.
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Payments do not act as a barrier to the development of e-commerce otherwise e-commerce would not have experienced continuous fast growth.
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