The European Payments Council (EPC) supports the European Commission’s overall objective of “creating a true European market for retail financial services”. However, the green paper does not appear to recognise the achievements of the payments industry to date in harmonising payments in Europe (development of and migration to SEPA schemes, card standardisation).
The EPC would be interested to know how the European Commission defines and measures the quality of products when calling for “better products”. The EPC’s view is that such an assessment should be left to the market and in particular to end-users and free competition.
The EPC would also be interested to see the analysis and understand the reasons behind the statement that air travel is an example of “a well-developed Single Market”. For example, in Section 2.1, the question arises about whether the concentration of service providers is actually not lower in the retail financial sector in comparison with the air travel sector taken as an example of a “well-developed Single Market”.
The EPC has concerns about the reference to the “portability of bank account numbers” mentioned in Section 2.1. The EPC is unaware of the existence of any feasibility, impact or cost and benefit analysis supporting such an option.
Overall, the paper seems to rely largely on anecdotal evidence. The EPC expects this to be complemented with analysis and rigorous quantitative research as the basis for public policy or any legislative initiative.
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