Sector reports
Spark 02 Sector reports October 2026

The liability flip.

Europe is rewriting its payment rules. When a scam call empties someone's account, the bank will often be the one paying it back. And the data banks sit on is about to get a price. Here is what changes, who feels it first and what you can build on top.

€4.2bn
payment fraud in the EEA in 2024 [1]
85%
of credit transfer fraud losses were carried by users [1]
~40
EBA mandates expected under PSD3 and PSR [6]
48
months until the last FiDA data phase opens, in the latest compromise [7]
01 The short version

Three laws, one big shift. Banks carry more of the risk and data gets a price tag.

PSR · Regulation

The rulebook for how money moves. Every EU country now reads the exact same text.

Conduct rules move from a directive into a regulation, so Germany, France and Lithuania read the same text. Fraud liability, payee checks, open banking APIs and fee transparency live here. [3]

PSD3 · Directive

The licence side. Payment and e money institutions end up under one roof.

PSD3 repeals PSD2 and the E Money Directive. Authorisation and supervision stay national. Existing firms get a transition window to show they meet the new rules. [3]

FiDA · Regulation

Open banking grows up. Savings, loans, investments and insurance data join the party.

Data holders join sharing schemes, can charge reasonable compensation and must give customers a permission dashboard. Still under negotiation, and narrower than the 2023 proposal. [7] [8]

Our view

PSD2 forced banks to open a door. This package makes them responsible for what walks through it, and FiDA lets them charge for the hallway. The winners will treat compliance work as product work.

02 Where things stand

One package is crossing the finish line. The other is still in the room.

PSD3 and PSR are agreed. The Council finalised its first reading position on 21 October 2026 and Parliament's final vote is pencilled in for the December plenary. Publication follows in early 2027, so most rules apply in late 2028. FiDA has no deal yet. [12] [14]

28 Jun 2023 Commission proposes PSD3 and PSR, on the same day as FiDA. Done
Apr 2024 Parliament adopts its first reading position, just before the European elections. [15] Done
Jun 2025 Council agrees its mandate. Trilogues start on 9 July. [15] Done
27 Nov 2025 Political agreement after the final trilogue in Strasbourg. [2] Done
23 Apr 2026 Final compromise texts published after Coreper approval. [3] Done
5 May 2026 ECON committee approves the texts. [5] Done
21 Oct 2026 Council finalises its first reading position on both texts. [14][15] Done
14 to 17 Dec 2026 Parliament's final vote, indicative date in the December plenary. [12] Next
Early 2027 Official Journal. Entry into force 20 days after publication. [12] Expected
+21 months Most PSR rules apply and PSD3 must be in national law. Late 2028. [13] Expected
+27 months Payee check for all credit transfers and its refund rules apply. Last date for existing licences to prove compliance. [13] Expected
03 Already live

Part of the flip already happened. German banks have run payee checks for a year.

The Instant Payments Regulation pulled some of the hardest builds forward. Banks have shipped them. PSR mostly adds the liability on top. [25]

Payee check, first year across the euro area

Share of check results, EPC data presented in August 2026. About 2.2 billion checks in the second quarter alone. [24]

66.2% Match. Name and IBAN fit.
16.2% Close match. The bank shows the right name.
15.4% No match. Warning before you pay.
2.2% Check not possible or failed.
What German users say

forsa survey for the Federation of German Consumer Organisations, 1,030 online banking users, August 2026. [22]

91%

like the payee check in principle

27%

rate the way banks run it today as bad

58%

of those warned see a warning on about every fourth transfer or more

What the rollout taught
  • Company names with legal form suffixes like GmbH, or small spelling differences, trigger a close match or no match. [23]
  • A missing second first name, swapped names or a hyphen can be enough for a warning. Consumer groups now ask for smarter matching. [22]
  • Some customers stopped payments even on a close match because the liability notice scared them. [23]
  • Older banking software broke until it was updated. Loan, savings and call money accounts sit outside the check. [23]
  • Today a customer who pays after a warning carries the loss. Under PSR, a bank that fails to warn pays it back. [10] [13]
Our view

False alarms are now the real risk. If customers learn to click every warning away, the PSR refund rule will hit the banks with the weakest name matching hardest. Better matching is a product advantage today, two years before the liability lands.

Other pieces already running
9 Jan 2025 Live Every euro area bank receives instant transfers, and an instant transfer cannot cost more than a normal one. [25]
9 Oct 2025 Live Sending instant transfers, the payee check and daily sanctions screening become mandatory in the euro area. [25]
Oct 2025 Live Payment and e money institutions can join T2 and TIPS directly if they meet the ECB's conditions. [25]
18 Nov 2025 Live Wero goes live for online shopping in Germany through Sparkassen and Volksbanken. Deutsche Bank, Postbank and ING followed, N26 joined in August 2026. About three quarters of retailers are still waiting to see if it takes off. [26] [27]
Nov 2026 Next Payee check rulebook 2.0 due from the European Payments Council, with an inquiry and compensation process on the table. [28]
9 Apr 2027 Next Payment and e money institutions in the euro area must send and receive instant transfers too. [25]
9 Jul 2027 Next Payee check reaches non euro countries such as Poland, Sweden and Romania. [25]
04 What changes

Flip the switch. Same situation, two rulebooks.

The fourteen changes we think matter most. Flip between the old and the new rules and see what it looks like in real life.

Most rules apply 21 months after entry into force, expected late 2028 [12] [13]

Payee check

Payers

The bank checks payee name against IBAN for all credit transfers. If it fails to flag a mismatch, it refunds the payer. [3][10]

In practice You pay an invoice from Müller GmbH. The app shows no match before you confirm, because the IBAN belongs to someone else.

Bank impersonation

Banks

If a fraudster poses as your bank and you report it to the police and the bank, the bank must refund in full within 15 business days, or refuse with reasons if it suspects fraud or gross negligence by you. [2][13]

In practice A caller shows your bank's real number and talks you into a safe account transfer. The bank pays you back.

Altered payments

Banks

If a fraudster initiates or changes a transaction, the payment provider covers the full amount. [2]

In practice Malware swaps the IBAN in a payment you prepared. Your bank refunds the full amount.

Fraud toolkit

All PSPs

Real time monitoring, spending limits and blocking options for users, plus a legal basis to share fraud data between providers. [2][3]

In practice A customer sets a €500 daily limit for new payees in the app before travelling.

Platforms in the frame

Big platforms

Large platforms and search engines must check that financial advertisers are authorised. If they are told about fraudulent content and leave it up, they are liable to the bank that refunded the victim. [2][15]

In practice A fake bank ad stays online for days after a report. The bank refunds the victim and claims the money from the platform.

Telcos and spoofing

Telcos

Electronic communication providers must cooperate and share information with payment providers to fight fraud. [2][4]

In practice A telco flags calls that spoof a bank's number and passes the signal to the bank.

Open banking API

Banks, TPPs

The API becomes the only access route and must be as fast as the bank's own app. Banks publish performance figures every quarter, cannot demand a contract and face a list of banned obstacles. The fallback goes. [5][13][16]

In practice A payment initiation provider no longer has to push users through three extra screens in the bank's flow.

Permission dashboard

Banks

Banks give users a dashboard to see and withdraw data permissions for free. A withdrawn permission can be restored within 48 hours, and records stay for two years. [17][13]

In practice A user sees four apps reading her account and switches off two of them in one screen.

Data access consent

AISPs

The 180 day logic moves into law. The bank authenticates at first access, then the provider renews the customer's consent itself. [4][5]

In practice A budgeting app keeps working for six months without sending the user back to the bank.

One licence

PIs, EMIs

One payment institution regime with an electronic money subcategory. Existing firms reapply or prove compliance within the transition. [3][4]

In practice A Berlin EMI updates its licence file and keeps passporting across the EU.

Account access

PIs, EMIs

Banks can refuse or close accounts only on specific grounds such as anti money laundering rules. A vague financial crime risk is no longer enough, and refusals can be challenged with the supervisor. [18]

In practice A payment institution gets a refusal without a real reason and takes it to the supervisor.

Authentication for all

Banks

Strong authentication must be free, must not depend on a smartphone alone and must fit people with disabilities or low digital skills. [3][4]

In practice An 80 year old customer confirms payments with a card reader instead of an app.

Fees and cash

Consumers, retail

All ATM and conversion fees shown up front. Shops can give cash without a purchase, up to €150. A country may set a lower cap, but not below €100. [2][16]

In practice A drugstore till pays out €100 to a customer who buys nothing.

Phone wallets

Device makers

Phone makers and service providers must give payment providers access on fair, reasonable and non discriminatory terms. [2]

In practice A bank launches its own tap to pay wallet on every major phone.

05 FiDA, the open finance map

Drag the clock. Watch which data opens up.

Based on the phased plan in the April 2026 compromise paper. Months count from entry into force. Nothing here is final law yet. [7]

Phase 1 opens. Savings, consumer credit and motor insurance data. This is where switching and refinancing products start.

Payment accounts Already open under PSD2
Savings Phase 1 · 24m
Consumer credit Phase 1 · 24m
Motor insurance Phase 1 · 24m
Mortgages Phase 2 · 36m
Investments Phase 2 · 36m
Crypto assets Phase 2 · 36m
Personal pensions (PEPP) Phase 2 · 36m
Other credit Phase 3 · 48m
Creditworthiness data Phase 3 · 48m
Non motor insurance Phase 3 · 48m
Occupational pensions Out, opt in possible
Who joins Banks, insurers, investment firms and crypto providers as data holders. Licensed users as data receivers. Credit rating agencies, large corporate customers, small investment firms, small insurers and credit unions are out. [7]
New licence Financial information service provider, a new licence for firms that receive data without another financial licence. [11]
Schemes Data holders and users must join a financial data sharing scheme that sets standards, liability and dispute rules. [7]
Compensation Data holders can charge reasonable compensation, set in the scheme. The Commission can step in if outcomes are poor. [7]
Raw data only Only data that has not been substantially processed. A bank's own scores and enrichment stay private. [8]
Dashboard Customers see and withdraw every permission they have given, in one place.
Big Tech Open. Some states want gatekeepers fully excluded from receiving data, others only from the new licence. [7]
06 User story

Meet Selin. She will never read PSD3, but she will feel it.

Selin is 34 and works as a freelance designer in Berlin. Three moments over three years show how these rules land in a real life. Selin is made up, the rules are real. Moments two and three assume FiDA is agreed in 2027.

Selin's phone · Early 2029
Phone Incoming call · Your bank, Customer care It shows the bank's real number
Banking app Name check: no match. This IBAN does not belong to Account Security GmbH.
Banking app €8,400 refunded to your account.

The call

First the payee check warns her that the name and IBAN do not fit. If the caller still talks her into it, she reports it to the police and her bank. Because the fraudster pretended to be her bank, the bank has 15 business days to pay her back in full or explain why not. [3] [13]

The rule behind it

PSR payee check and the impersonation refund, applying from late 2028.

What companies need to build

Fraud signals that work in real time, a refund process that runs in days and a way to claim the money back from telcos and platforms.

07 Game · Who pays?

Six fraud cases. Guess who carries the loss under the new rules.

Take a guess before you read the answer. Based on the agreed PSR text. Real cases always depend on the details and on national courts.

Case 1 of 6

Malware on your laptop quietly changes the IBAN in a transfer you set up. €3,200 is gone.

08 Impact finder

Pick your company. See the bill and the upside.

Where does your company sit? We placed each type of player by what the rules will cost it and how much new revenue they open up. The scores are our own estimates from 0 to 10.

00551010123456789101112131415
1 of 15

Large universal banks

Rebuild
Compliance load 8
Revenue room 6
What changes

They carry the new fraud refunds, payee checks, API performance KPIs and the permission dashboard. Under FiDA they are the biggest data holders and can also be data users.

Next 12 months

Split API access into what the law makes free and a paid premium tier. Join a FiDA scheme early to shape compensation rules. Build recourse claims against platforms and telcos into fraud operations.

Use case · illustrative

A large bank keeps PSR account access free, then sells a premium API with enriched transaction data and higher call limits to lenders and accounting software.

09 Business models it sets off

Twelve things worth building on top of the new rules.

Every new rule creates a job someone will get paid for. Here are the twelve we find most interesting. Filter by who is best placed to build them. The use cases are examples.

Model 01

Premium API catalogue

Triggered by PSR keeps mandated data access free. FiDA allows reasonable compensation.
How it makes money Per call or subscription for data beyond the legal minimum.
Use case A bank sells real time balance alerts and categorised transactions to payroll software.
Banks
Model 02

Fraud intelligence network

Triggered by Impersonation refunds and a legal basis to share fraud data.
How it makes money Membership fees and per check pricing across banks.
Use case Twelve mid sized banks pool mule account signals through one provider and cut refunds.
BanksFintechs
Model 03

Payee check as a service

Triggered by Payee checks for all credit transfers with refund liability.
How it makes money Per check fee plus risk scoring on top of name matching.
Use case A provider adds company register data so a check flags a newly founded shell company.
Fintechs
Model 04

Recourse and claims engine

Triggered by Banks can claim from platforms, telcos and technical providers.
How it makes money Success fee on recovered refunds.
Use case A claims platform bundles fifty refunded cases and files them against one platform at once.
Fintechs
Model 05

Permission dashboard product

Triggered by PSR and FiDA dashboards are mandatory.
How it makes money White label licence. For banks, a retention screen.
Use case An insurer uses the dashboard to show which apps hold its data and offers its own app instead.
BanksFintechs
Model 06

Scheme operator

Triggered by FiDA requires financial data sharing schemes.
How it makes money Membership, certification and dispute services.
Use case An industry body runs the German insurance data scheme and certifies member APIs.
BanksFintechs
Model 07

Switching engine

Triggered by FiDA phase 1 and 2 data on savings, credit, mortgages and insurance.
How it makes money Commission from the new provider.
Use case A mortgage broker reads the current loan and alerts the client six months before the fixed rate ends.
FintechsNon financial
Model 08

Account to account checkout

Triggered by Cleaner payment initiation rules with banned obstacles.
How it makes money Lower fees than cards, shared with merchants.
Use case An online furniture shop moves large tickets to bank payment and saves card fees.
FintechsNon financial
Model 09

Cash as a retail service

Triggered by Cash without purchase in shops, up to €150 per withdrawal.
How it makes money Fees paid by banks or networks per withdrawal.
Use case A petrol station chain becomes the cash point for three regional banks.
Non financial
Model 10

Accessible authentication

Triggered by Free, inclusive authentication that does not rely on a smartphone alone.
How it makes money Hardware, voice and card based methods sold to banks.
Use case A vendor ships a voice based confirmation for visually impaired customers.
Fintechs
Model 11

Advertiser verification

Triggered by Financial advertisers on large platforms must prove authorisation.
How it makes money Per advertiser check sold to platforms and agencies.
Use case A verification API checks the national licence registers before a finance ad goes live.
FintechsNon financial
Model 12

Bank wallet on any phone

Triggered by Fair access to NFC and secure storage.
How it makes money Keeps card economics and the customer relationship in the bank.
Use case A bank group launches one tap to pay wallet for all its member banks.
Banks
10 UK lens

The UK already lives in the future the EU is planning. Two years in, here is what it learned.

Since 7 October 2024, UK banks and fintechs must refund most scam victims, even when the customer pressed send. The rule split the industry and it is live. Below are the rules, the numbers, the fights and what we learned building fraud flows for a UK digital bank launch at RUUT.

EU, PSRUK, mandatory reimbursement
StatusApplies from late 2028 [12]Live since 7 October 2024 [29]
Which scamsImpersonation of the customer's own bank, and failed payee checks [13]Almost every authorised push payment scam over Faster Payments [30]
Who paysThe payer's bank, with recourse to platforms and technical providers [4]Split 50/50 between the sending and the receiving firm [30]
How fast15 business days to refund or refuse with reasons [13]5 business days, up to 35 when more evidence is needed [29]
LimitsFull amount, unless fraud or gross negligence by the customer [13]Cap of £85,000, optional excess up to £100, a consumer standard of caution [29]
What the first 18 months show
88%

of money lost to in scope scams paid back, £316m in 18 months [29]

82%

of claims closed within five business days [29]

£73m

less lost to scams a year, a fall of about 21% [31]

£21m → £60m

international scams outside the rule, 2023 to 2025 [30]

Independent evaluation by Frontier Economics for the PSR, July 2026, and the PSR reimbursement dashboard to March 2026.

Why it caused a fight

Banks pay for fraud that mostly starts somewhere else.

54% of scams start on Meta's platforms, yet the refund bill lands only on payment firms. [36] Smaller fintechs said a few large cases could wipe out a year of margin. Refund rates range from 21% to 94% across firms, and one firm used the customer caution exception in over a quarter of cases by value while others never did. Fraud is also moving to crypto exchanges and overseas transfers, where the rule stops. [30]

What else the UK runs

The UK built the toolbox around the refund rule.

Confirmation of Payee has run since 2020 and now covers more than 320 firms and over 99% of Faster Payments senders. In October 2026 the regulator removed its expiry date. [32] Banks may hold a suspicious payment for up to four extra days. [33] Open banking recurring payments got their own industry scheme in June 2026. [34] The PSR itself is being folded into the FCA, the bill now sits in the Commons. [35] A consultation on fixing the refund rule follows in December 2026. [30]

Follow a scam payment through a UK banking app

Tap each step. These are defences UK banks and fintechs run today, many of which we designed or chose partners for at RUUT. EU teams can copy what worked.

What it stops

Safe account and bank impersonation scams, where a caller coaches the victim live.

From the field Alert during a phone call If the customer opens the app while on a call, a banner asks: is someone on the phone telling you to move money? Your bank will never do that.
From the field No screen sharing The app blocks screen recording and screen sharing, so remote access scammers cannot watch codes or balances.
Telco signals Spoofed numbers and calls from unknown sources become a risk signal. In the UK this is still mostly voluntary.
Our view

The UK proves refund rules change behaviour, losses fell within a year. It also proves fraud moves to wherever the rules stop. EU banks have two years to build calmly what UK firms had to build in a rush.

11 Expert note
Mehmet Burak Dikmen
I built digital banks under PSD2. Compliance was the big topic back then too. What is new with PSD3 is that it opens the way to better, more flexible financial services and new products that actually mean something to people.

Fighting these rules is wasted energy. Building them into the product and turning them into something useful for customers is one of the smartest moves any bank, fintech or company can make right now.

FiDA goes even further. It brings new opportunities, new business models and some fresh air into competition. Fintech and banking have exciting years ahead.

Mehmet Burak · fspark9

  • Map every money movement flow against payee check and impersonation refund exposure.
  • Price your API. Know what is free by law and what can be premium.
  • Pick your FiDA role per product line: data holder, data user, or both.
  • Write a recourse playbook for platforms, telcos and technical providers.
  • Turn the permission dashboard into a product with a product owner.

The rules are written. What you build on them is still open.

fspark9 helps banks, fintechs and companies with customers turn regulation into product decisions.

Sources

Where every figure comes from.

  1. [1] EBA and ECB, 2025 Report on Payment Fraud, December 2025. www.ecb.europa.eu
  2. [2] European Parliament, Payment services deal: more protection from online fraud and hidden fees, November 2025. www.europarl.europa.eu
  3. [3] Arthur Cox, PSD3 and PSR: final compromise texts published, April 2026. www.arthurcox.com
  4. [4] Freshfields, PSD3/PSR: what the EU's new payments rules mean for your business, 2026. www.freshfields.com
  5. [5] Open Banking Tracker, PSD3 and PSR readiness and timeline, 2026. www.openbankingtracker.com
  6. [6] Linklaters, Payments in 2026 #3: PSD3. financialregulation.linklaters.com
  7. [7] Council of the EU, Interinstitutional file 2023/0205 (COD), FiDA compromise paper, 6 April 2026. data.consilium.europa.eu
  8. [8] Projective Group, FiDA back in motion: from ambitious to workable, May 2026. www.projectivegroup.com
  9. [9] Freshfields, Risen from the ashes: FIDA trilogue set to move forward, March 2025. www.freshfields.com
  10. [10] Regulation (EU) 2024/886 on instant credit transfers in euro. eur-lex.europa.eu
  11. [11] Banking.Vision, Open Finance: FIDA taking shape as lighter, consumer centric regulation, September 2025. banking.vision
  12. [12] Clifford Chance, Regulatory horizon scanner EU and UK H2 2026: fintech firms, July 2026. www.cliffordchance.com
  13. [13] Herbert Smith Freehills Kramer, The new EU payments rulebook (PSD3/PSR), May 2026. www.hsfkramer.com
  14. [14] Norton Rose Fulbright, Regulation Tomorrow: Council publishes PSD3 first reading position, 23 October 2026. www.regulationtomorrow.com
  15. [15] Council of the EU, Statement of reasons on the PSR first reading position, 8543/26 ADD 1 REV 1, 21 October 2026. data.consilium.europa.eu
  16. [16] Alston and Bird, PSD3 and PSR: what changes for business operations in Europe, October 2026. www.alston.com
  17. [17] Addleshaw Goddard, PSD3: a new era for EU payment services regulation, September 2026. www.addleshawgoddard.com
  18. [18] Projective Group, Will PSR and PSD3 solve the account access problem for payment institutions?, September 2026. www.projectivegroup.com
  19. [19] Council of the EU, Cypriot presidency note on the future of FiDA, WK 4626/2026, 25 March 2026. data.consilium.europa.eu
  20. [20] Konsentus, FiDA's timetable might shift, but the destination won't, November 2025. www.konsentus.com
  21. [21] France FinTech, FiDA regulation: between French mistrust and British optimism, April 2026. francefintech.org
  22. [22] Verbraucherzentrale Bundesverband (vzbv), Mehr Last als Schutz: so verfehlt die Empfängerüberprüfung ihr Ziel, 9 October 2026. www.vzbv.de
  23. [23] IT Finanzmagazin, Von ruckelig bis problemlos: Erfahrungen bei der Einführung von VoP, March 2026. www.it-finanzmagazin.de
  24. [24] Qombo, Verification of Payee one year later, citing EPC data from August 2026, October 2026. www.qombo.tech
  25. [25] European Central Bank, Instant Payments Regulation deadlines and obligations. www.ecb.europa.eu
  26. [26] The Paypers, Wero ecommerce is now live in Germany, November 2025. thepaypers.com
  27. [27] EuroShop, Wero 2026: reticence in online retail, August 2026. www.euroshop-tradefair.com
  28. [28] EPC status update on payment schemes for the ERPB, June 2026. www.ecb.europa.eu
  29. [29] Payment Systems Regulator, APP scams reimbursement dashboard, Q1 2026. www.psr.org.uk
  30. [30] Bratby Law, APP fraud reimbursement: the evaluation verdict, on the Frontier Economics evaluation for the PSR, July 2026. bratby.law
  31. [31] Norton Rose Fulbright, Regulation Tomorrow: Payment fraud falls by £73m following PSR reimbursement scheme, July 2026. www.regulationtomorrow.com
  32. [32] Norton Rose Fulbright, Regulation Tomorrow: PSR publishes Specific Direction 17 (Confirmation of Payee), October 2026. www.regulationtomorrow.com
  33. [33] The Paypers, UK banks now able to investigate suspicious transactions within four days, 2024. thepaypers.com
  34. [34] Financial Conduct Authority, Open banking takes next step forward with launch of UK Payments Initiative scheme, June 2026. www.fca.org.uk
  35. [35] Bratby Law, Financial Services and Markets Bill 2026, updated October 2026. bratby.law
  36. [36] Payment Systems Regulator, Unmasking how fraudsters target UK consumers in the digital age, December 2024. www.psr.org.uk

Status checked on 26 October 2026. The Parliament vote, publication and application dates for PSD3 and PSR are indicative dates from the institutions' calendars and law firm trackers. FiDA is still under negotiation, so phases, scope and gatekeeper treatment can change. Impact scores, sector verdicts and use cases marked as our view are fspark9 analysis and do not constitute legal advice.