On 19 December 2018, the FCA published an updated approach document (version 3) on payment services and electronic money. The approach document describes the FCA’s approach to implementing the Payment Services Regulations 2017 and the Electronic Money Regulations 2011, and is aimed at businesses that are, or are seeking to become:

  • authorised payment institutions or small payment institutions (collectively – PIs);
  • authorised e-money institutions or small e-money institutions (collectively – EMIs;
  • registered account information service providers (RAISPs); and
  • credit institutions, which must comply with parts of the PSRs 2017 and EMRs when carrying on payment services and e-money business

The approach document amends version 2, from July 2018 (our blog is here) of the FCA’s approach, by introducing new guidance on authentication and secure communication under the Payment Services Directive – impacting chapters 17 and 20. Minor changes have also been made to clarify the FCA’s guidance and reflect legislative change. These changes impact chapters 1, 3, 6, 8, 13, 18, 19.