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We have seen that the PSD 2 directive removes the “surcharges” (surcharges that merchants charged consumers for the use of means of payment) and provides in certain cases that payment service providers must apply for a license from the National Bank. to provide payment services.

The DSP2 directive is also starting a revolution in the financial world which would make it possible to do without means of payment.

This development is known as "open banking" and consists in forcing financial institutions to share their customers' data with certain third parties which offer payment services but also with merchants (TPP-Third Party providers) via "API" (Interfaces which allow the exchange of data) .

The PSD 2 directive creates the framework and the obligations of these third parties to be able to benefit from "open banking" and gives the competence to the national banking authority to issue approvals.

The benefit of payment initiation services (PISP) for online merchants.

For a long time, the idea of being able to transfer funds directly from the account of an individual (consumer) to the account of another person or a company without going through the intermediaries that offer payment services has been considered. This is the interest of PISPs

This system therefore allows authorized traders to submit a payment request for their consumer to their bank via the bank's API.

Of course, it is still possible to pay for purchases by credit card and take advantage of the protections and services offered by card systems and their issuers, but the introduction of PISP offers consumers additional choice.

Convenient operation and strong customer authentication system.

If a consumer chooses to pay for their purchases through a bank account and gives their consent, the merchant, the payment initiation service provider (PISP - in this case the merchant) can request permission to securely access to their bank account (via API platforms provided by banks).

The PISP (merchant) will of course not have access to the accounts themselves (unless he has another authorization as an account manager) and will only receive, following his request, a response relating to the availability of funds. requested.

In terms of security, the initiation request is based on "strong client authentication" which means authentication based on the use of two or more elements belonging to the "knowledge" categories (something that only the user knows about). ), “Possession” (something that only the user has) and “inherence” (something that the user is) and independent in the sense that the compromise of one does not call into question the reliability of the others, and which is designed to protect the confidentiality of authentication data;

The technical elements and their implementation can be found in detail in the “RTS” which are technical standards published very recently by the European Banking Authority.

The accreditation procedure with the National Bank of Belgium

Payment institutions

The PSD2 directive defines a “payment institution” as any legal person which has obtained an authorization authorizing it to provide and perform payment services throughout the Union;

The law of 11 March 2018 relating to the status and control of payment institutions (...) which partially transposes the PSD2 directive into the Belgian legal order confirms that companies other than “traditional” payment service providers can provide the services payment services listed in Article 8. (These services include payment initiation services)


Approval is granted by the National Bank of Belgium if the information and supporting documents provided by the candidate accompanying the request meet all the conditions set by law.

Without claiming to be exhaustive, these documents include the candidate's activity program, his business plan, obtaining the required capital, the description of organizational and security measures and more specifically for applicants who want to provide payment initiation services; taking out civil liability insurance.

Territorial application

In terms of its territorial application, one of the advantages of approval is that it automatically includes a “European passport” which allows the company to carry out its activities in other EU member states.

A recent example of a company having obtained approval in Belgium

Worldline, the European leader in payment and transaction services, has obtained approval to become a payment initiation service provider (PISP)

As a PISP, Worldline can now present and launch payment transactions by transfer on behalf of B-to-B and B-to-C customers, offering a new payment method, with a simplified user experience for consumers and for traders.


It remains to be seen whether in practice this opportunity will be seized by traders given the requirements to obtain approval, particularly with regard to capital and the implementation of technical and security measures.

You have questions relating to this subject, do not hesitate to contact me by sending me an email.

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