On 5 December 2025, the European Banking Authority (EBA) published a follow-up peer review report on authorisations under the revised Payment Services Directive (PSD2).

Background

The report follows-up on the EBA’s 2023 peer review report on the authorisation of payment institutions and electronic money institutions under the PSD2. It also discusses the extent to which supervisors have implemented the recommendations from the earlier peer review report in areas such as authorisation processes, implementation of EBA guidelines on authorisation, governance and internal controls, anti-money laundering frameworks and local substance.

Key points

Key points in the follow-up report include that while notable improvements and increased convergence have been observed, significant differences persist in certain key areas such as governance, internal control mechanisms, and local substance. These divergent implementations continue to pose risks of regulatory arbitrage and an uneven playing field across Member States.

The follow-up report also notes that during 2022-2024, most supervisors saw a decline in new applications compared to 2019-2021, with only a few reporting increases. Application volumes and authorisation timelines continue to vary widely across Member States, ranging between 4-6 months and up to 27 months in one Member State, and with a median duration of 9.5 months excluding that Member State. Delays are most often attributed to incomplete or low-quality applications and the time applicants take to address deficiencies.