Banking Regulation in Transition

Payment Transactions, Open Finance, and Digital Infrastructure
This white paper provides a concise overview of the most important developments through 2029 and distinguishes between mandatory requirements, ongoing implementations, and planning objectives. It also highlights the measures banks can already take in a structured manner today.
What You’ll Find in the White Paper
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Regulatory Timeline: 2024–2029
An overview of key milestones with a clear distinction between current requirements and planned deadlines. -
PSD3, PSR, and Instant Payments
An analysis of changes regarding licensing, supervision, fraud prevention, liability, customer authentication, and third-party access. -
FIDA and Open Finance
An overview of the planned access to financial data beyond payment accounts and the resulting requirements for data, APIs, and consent. -
Digital Euro
Distinction between the EU legal framework, the ECB decision, the Scheme Rulebook, pilot programs, and a possible future issuance. -
Cross-Sector Regulation
Interplay between DORA, MiCA, AMLR, AMLD6, AMLA, the AI Act, eIDAS 2, and the EUDI wallet. -
Action Plan for Banks
Six specific areas of focus for coordinated regulatory and technical preparation.
Regulatory Change: What Banks Should Be Preparing Now
The key challenge lies in deriving clear priorities for organization, technology, and control from regulatory developments. By aligning deadlines, dependencies, and responsibilities early on, banks can avoid duplication of effort and reduce implementation risks down the line.
For banks, this results in four key priorities:
- Manage Deadlines Effectively: Clearly distinguish between binding requirements, relative implementation deadlines, and policy planning goals.
- Integrate architectures: Consider payments, APIs, digital identity, AML, fraud, and DORA as a unified whole.
- Organize data and controls: Ensure that data quality, authorizations, consents, and evidence are designed to withstand regulatory scrutiny.
- Prepare scenarios early: Coordinate fraud and sanctions processes and examine potential roles related to the digital euro.
Early, coordinated architecture decisions can prevent duplication of effort and significantly reduce implementation risks down the line.

Download the white paper
Get a concise overview as a PDF and use the regulatory timeline, status overview, and action plan for your internal planning.