All Positions

EFA contibution to call for evidence on online fraud

Approaches to combating online fraud The European FinTech Association (EFA) welcomes the opportunity to contribute to the European Commission’s (Commission) action plan on online fraud.  We believe that to effectively prevent and mitigate online fraud, all players in the fraud chain must collaborate closely and establish practices to prevent fraud from originating from, or taking […]

Opportunities for strengthening the EU’s AML regulatory framework through proportionate, risk-based implementation

The EU’s Anti-Money Laundering (AML) Package represents a significant step toward greater harmonisation, stronger financial integrity, and enhanced protection of EU citizens and businesses. As the Anti-Money Laundering Regulation (AMLR) moves toward implementation, there is an opportunity to ensure that its practical application fully delivers on these objectives while preserving proportionality, a genuine risk-based approach, […]

European FinTech Association position on the Financial Data Access (FiDA) Regulation

To: European Parliament, European Commission and Council of the EU  On behalf of the European FinTech Association (EFA), we are writing to reiterate our support for the Financial Data Access (FiDA) Regulation and to urge all co-legislators to conclude the trilogue negotiations swiftly and ambitiously. FiDA is widely recognised as the essential catalyst for Open […]

Strengthening consumer protection and competition through a shared liability regime in the PSR

On behalf of the European Fintech Association (EFA) and the European Digital Payments IndustryAlliance (EDPIA) we would like to emphasise the importance of introducing a shared liability regime forimpersonation fraud under article 59 and relevant Recitals in the final text of the EU Payment ServicesRegulation (PSR), which is currently under negotiation. Authorised push payment (APP), […]

EFA response: EU Single Market Strategy 2025

The European Fintech Association (EFA) would very much welcome a new European Commission strategy to reduce fragmentation, reinforce the eorts to complete the EUs Single Market and reduce the overall regulatory burden on the market. The EFA has been actively supporting the development of a robust (Digital) Single Market,which would benefit all businesses, including financial […]

Joint Industry Letter for Effective and Efficient Fraud Prevention in Europe

Brussels, 10 June 2024: As representatives of the digital payments and technology sectors, we would like to express our appreciation for the ongoing work on the EU Payments Package. The EU Commission’ draft proposal for the Payments Services Regulation (PSR) already includes provisions to prevent and mitigate fraud risks, such as verification of payee for […]

EFA view on virtual IBANs

The EFA is pleased to observe the ongoing work of the Council of the EU regarding the review of the Payment Services Directive and the new Payment Services Regulation (PSRD), and the progress made with regards to fraud prevention and mitigation. Recently, we have observed suggestions made regarding virtual IBANs, and would like to bring […]

Joint Statement on the treatment of Merchant Initiated Transactions under the Payment Services Regulation

Under its new proposal for a Payment Services Regulation (PSR), from 28 June 2023, the European Commission reinforced the refund rights for merchant-initiated transactions (MITs). It does so by extending the unconditional refund right under Article 62(1) that exists for direct debits (DDs) to all MIT transactions. In essence, this means that payers would be […]

EFA Position on the Digital Euro Regulation

Introduction The European FinTech Association (EFA) welcomes the Commission’s proposal on the Regulation to establish the digital Euro. The EFA supports an open and competitive payment landscape. If correctly designed, the digital euro could generate new competitive value chains with potential benefits to consumers and businesses. However, whilst the proposal considers that financial exclusion in […]

Joint statement of ETPPA, EMA, EPIF, EFA, and OFA on: AMLR technical trilogues – RECITAL 34 discriminating against  European fintechs

Brussels, January 31, 2024: Following up on the joint EU fintech industry statement issued on May 17, 2023 (see here), ETPPA, together with EMA, EPIF,  EFA  and OFA, are calling on the co-legislators and the European Commission to clarify the compromise text reached on recital 34 of the AML Regulation in the technical trilogues; this […]

Joint industry letter on foreign exchange rate transparency in cross-borderpayments and the use of an aggregated live mid-market benchmark rate

As representatives of the financial services and payments sector, we would like to express our appreciation for the ongoing work on the Payment Services package (PSD3/PSR), which has the potential to greatly improve the functioning of the payments market within the EU and beyond.

Joint Industry Statement on AI Definition

In the wake of the December 2023 political agreement on Artificial Intelligence regulations, financial industry representatives stress the need to safeguard ongoing credit scoring operations from potential disruptions caused by pending technical details around the agreed definition of “artificial intelligence systems”. Credit scoring is a vital element of the financial sector, providing a way to evaluate an individual’s creditworthiness based on their financial history and behaviour. This evaluation assists lenders in making well-informed decisions about extending credit or loans.

EFA- ETPPA Joint Position paper on the AMLR

This document presents the European Fintech Association (EFA) and European Third-Party Providers Association (ETPPA) comments regarding the inclusion of PISPs on the AMLR scope.

EFA Sustainability Position Paper

The European Fintech Association welcomes recent initiatives of the EU to encourage sustainability in financial services. We believe fintech, especially the cryptoasset sector, can play an important role in driving sustainable innovation. With the right approach, the EU can empower the cryptoasset industry to drive positive change, foster sustainable practices, and contribute significantly to the green transition.

EFA Position on the Proposal for a Regulation on a framework for Financial Data Access

The European Fintech Association (EFA) warmly welcomes the opportunity to share its position on the Proposal for a Regulation on a Framework for Financial Data Access (FIDA). The EFA represents a diverse group of 35+ FinTech providers ranging from payments, to lending, banking, robo-advice, investment as well as software-as-a-service for the finance sector, with a clear focus on enabling a single market for digital financial services. EFA believes that, if done right, FIDA has the potential to be a catalyst for further competition in the financial services market to the benefit of the European consumer.

Position Paper on the Revised Payment Services Directive & Regulation

The European Fintech Association welcomes recent initiatives of the EU to encourage sustainability in financial services. We believe fintech, especially the cryptoasset sector, can play an important role in driving sustainable innovation. With the right approach, the EU can empower the cryptoasset industry to drive positive change, foster sustainable practices, and contribute significantly to the green transition.

EFA Position on the Digital Euro Proposals

The European FinTech Association (EFA) welcomes the Commission’s proposal on the Regulation to establish the digital euro. The EFA supports an open and competitive payment landscape. If correctly designed, the digital euro could generate new competitive value chains with potential benefits to consumers and businesses.

EFA Statement on the Provisional Agreement on the Instant Payments Regulation

The European Fintech Association (EFA) welcomes the provisional agreement reached by the European Parliament and the Council of the EU on 7 November 2023. The Instant Payments Regulation (IPR) is a major step forward in enabling consumers and merchants across Europe and globally to benefit from the wide range of benefits that instant payments offer. […]

EFA position paper on AMLR

This document enumerates the treatment of various issues of interest to EFA within the AMLR by the Commission, Parliament, and Council texts, and presents EFA’s views on each. It includes brief explanations of each position.

EFA- ETPPA joint proposition paper on the AMLR

This document presents the European Fintech Association (EFA) and European Third-Party Providers Association (ETPPA) comments regarding the inclusion of PISPs on the AMLR scope.

EFA position paper to the AMLD

You can find the PDF version of the position paper here.

EFA response to the EBA Consultation on revised Guidelines AML risk factors

You can find the PDF version of the full position paper here The European Fintech Association (EFA) welcomes the EBA’s proposal on amendments to its Guidelineson money laundering and terrorist financing (ML/TF) risk factors to include CASPs. The EFA fully supports a harmonized ML/TF Regime containing clear rules aimed at improving thedetection of suspicious transactions […]

EFA Position Paper on the Retail Investment Strategy

EFA shares the belief that retail investors must be empowered to make more informed investment decisions that better correspond to their needs and objectives and that retail investors must be adequately protected in the single market. Below we share key areas of the RIS the EFA believes can be improved upon to achieve the European Commission’s stated goal

Joint industry letter on amending the Settlement Finality Directive alongside the Instant Payments Regulation to boost the uptake of instant payments and ensure a level playing field for all

Joint industry letter on amending the Settlement Finality Directive

European Fintech Association position paper on crypto assets under the anti-money laundering regulation

In line with our previous position papers,we believe that the comments presented in this document addressing specific crypto-related matters in the AMLR text will help harmonize and enhance theeffectiveness of anti-money laundering and countering financial terrorism(ML/FT) rules across Europe.

Statement by the European FinTech Association on the proposals Payment Services Directive (PSD3/PSR); The Digital Euro and the Framework for Financial Data Access (FIDA)

Statement by the European FinTech Association on the proposals Payment Services Directive (PSD3/PSR); The Digital Euro and the Framework for Financial Data Access (FIDA)

Joint industry letter to ensure payments are kept in scope of the Digital Identity Regulation

EFA submitted a joint industry statement calling on co-legislators to ensure payments are kept in scope of the Digital Identity Regulation.

Joint Industry letter on the Instant Payments proposal

The European Fintech Association partnered up with other trade associations to publish a joint industry letter welcoming and strongly supporting the European Commission’s recent legislative proposal on instant payments.

Joint industry letter on amending the Settlement Finality Directive (SFD)

EFA submitted a joint industry letter regarding the importance of fair access to infrastructure to create a level playing field and make instant payments a success in Europe

EFA Position Paper on the Instant Payments Proposal

The European FinTech Association (EFA) welcomes and supports the European Commission’ proposal to accelerate the rollout of instant payments for the benefit of citizens and businesses in the EU, including SMEs. EFA would like to feed into the current legislative work on the Instant Payments proposal

EFA Position Paper on the Artificial Intelligence Act

The European FinTech Association (EFA) welcomes the European Commission’s (Commission) legislative proposal on Artificial Intelligence (AI) to promote the development of AI in Europe. We would like to provide with this position paper a set of recommendations.

EFA Position Paper on the Revised Payment Services Directive 2

The European FinTech Association (EFA) welcomes the European Commission’s (Commission) review of the Payment Services Directive 2 (PSD2). PSD2 has delivered a more innovative, competitive payments landscape in Europe, however, challenges remain in its implementation.

EFA Position Paper on Open Finance

The European Fintech Association’s (EFA) vision is for European FinTechs to be the most innovative and competitive in the world, providing European consumers with solutions to meet their individual needs. If done right, the open finance framework can prove to be a game changer for the industry.

EFA Statement on the Transfer of Funds Regulation

The European FinTech Association (EFA) welcomes the efforts of the European Commission, Council, and European Parliament on the proposed anti-money laundering package which will ensure a harmonized European framework to prevent money laundering and counter-terrorist financing (ML/TF) in the EU.

EFA Policy Paper on the Issuance of a Digital Euro

The European FinTech Association (EFA) welcomes the discussion around the digital euro and the various considerations on its upcoming design. The EFA supports an open and competitive payments landscape. If correctly designed, the issuance of a digital euro could transform the economy, generating new

EFA Statement on the European Payments Initiative

The European FinTech Association (EFA) supports the European Commission’s aim to encourage a more innovative and competitive EU retail payments market. EFA believes the European Payments Initiative (EPI) can contribute to this objective

EFA input on upcoming Commission Instant Payments legislation

The EFA welcomes and fully supports the Commission’s plans to put forward a legislative initiative on instant payments to promote adherence to SCT Inst. Legislation is necessary to further accelerate the uptake and roll-out of instant payments in the EU.

EFA’s Response to the EBA’s Consultation on Remote Customer Onboarding Guidelines

The European Fintech Association (EFA) welcomes the opportunity to participate in the European Banking Authority’s (EBA) consultation on its draft Guidelines on the use of remote customer onboarding solutions.

EFA Statement on AI

The European FinTech Association (EFA) welcomes the European Commission’s (Commission) legislative proposal on Artificial Intelligence (AI) to promote the development of AI in Europe, and fully supports its intention to protect the privacy of European citizens.

EFA Position Paper on the EU Retail Investment Strategy

The European FinTech Association (EFA) welcomes the European Commission’s work on a dedicated Retail Investment Strategy. We agree that the ultimate goal of the Capital Markets Union cannot be attained without a meaningful inclusion of retail investors.

EFA Policy Statement on Basel III

The European FinTech Association (EFA) welcomes the European Commission’s (Commission) proposal to review the Capital Requirements Regulation and the Capital Requirements Directive, implementing the Basel III agreement in the EU.

EFA Position on the Consumer Credit Directive Review

Fintechs welcome the Review of the Consumer Credit Directive as a necessary step to bring the legislation up to…

EFA publishes its position on the proposed AML Framework

EFA Position Paper: Towards a harmonised Anti-Money Laundering Framework.

EFA Position on the Settlement Finality Directive Review

FinTechs support fair access to payment systems: EFA’s Position Paper on the Settlement Finality Directive (SFD) review.

EFA Policy Statement on e-IDAS Regulation

The EFA welcomes the European Commission’s proposal on the review of the e-IDAS regulation as a significant and positive step towards removing cross-border barriers in the EU, and building a more harmonized and accessible financial services landscape for European businesses and consumers.

EFA position paper on the Artificial Intelligence legislative proposal

The European FinTech Association (EFA) welcomes the European Commission’s (Commission) recent legislative proposal on Artificial Intelligence (AI) to promote the development of AI in Europe, and fully supports its intention to protect the privacy of European citizens.

Creating an Ecosystem that will allow EU FinTechs to Thrive

The EFA warmly welcomes the call for evidence on digital finance by the ESMA and the possibility to provide its input. The EFA represents more than 30 leading FinTech companies of all sizes across the EU that are active in different business areas.

EFA responds to European Commission’s Consultation on Instant Payments

The EFA fully supports the European Commission’s vision for retail payments including a competitive, innovative payments market. Making instant payments the new norm and promoting fair and equal access to critical infrastructure is key to achieving a truly competitive payments landscape.

EFA publishes position on European Retail Payments

The European FinTech Association (EFA) published today its position on a European Payments Strategy.

EFA publishes position on European Digital Identification

The European FinTech Association (EFA) has today published its position paper on a enabling interoperable digital identification in the EU.
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