PSD3 and PSR: Where Do Exemptions Apply? | ALLES LEGAL #107

🎧Which companies will need regulation – and which won’t? In Episode 107 of Alles Legal – Fintech-Recht kompakt, Peter Frey explains who falls under PSD3 and PSR – and where exemptions apply. Tune in now!

Podcast: https://paymentandbanking.podigee.io/734-alles-legal-107-psd3-und-psr-wer-fallt-kunftig-darunter-und-wo-gelten-ausnahmen/

New Rules, New Obligations – What Changes Under PSD3 and PSR?

In this episode, Peter Frey, lawyer and partner at Annerton in Frankfurt and author at PayTechLaw, joins host Dana Wondra from Payment & Banking to discuss the scope and implications of the new PSD3 Directive and the Payment Services Regulation (PSR).

Who Will Be Covered?

  • PSD3 remains focused on payment institutions
  • PSR also applies to banks, technical service providers, and system operators
  • E-money institutions will be treated as payment institutions
  • Providers of electronic communication services may now be included

Exemptions – Old and New

  • Existing exemptions like agents or voucher systems remain
  • Group exemption expanded to include external intra-group transactions
  • New: Retail cash withdrawals up to €150 without prior purchase

Registration Instead of Licensing

  • Account information services remain subject to registration
  • Independent ATM operators will now require registration

Collision With MiCAR: Double Regulation Ahead?

  • E-money tokens will fall under PSD3/PSR
  • Some exceptions are defined but remain complex
  • Crypto service providers may face additional hurdles

Next Episode Preview

Episode 108 will cover new liability rules, protections against social engineering, and shifting security responsibilities.

About this podcast

Alles Legal – Fintech Recht Kompakt delivers sharp, weekly insights into legal and compliance matters in the world of banking. (in German only)
This podcast is a collaboration between Payment & Banking and PayTechLaw.
Each Wednesday, we unpack the legal developments shaping the financial world – clearly, concisely, and without the legal jargon.
Since 2021, PayTechLaw authors and Annerton attorneys have brought depth and clarity to complex topics.
Whether it’s PSD3, DORA, or FiDA – we provide the legal context you need.
In 20 minutes. No detours.



By continuing, you accept our privacy policy.
You May Also Like
PFOF-Verbot
Read More

The PFOF ban comes into force: What the new BaFin supervisory statement means for brokers and neobrokers

Since 1 July 2026, the ban on Payment for Order Flow (“PFOF”) has also been in force for purely domestic business relationships in Germany. On 22 July 2026, BaFin published a supervisory statement on this matter, in which it sets out in concrete terms for the first time which business models it considers to be compliant with the rules - and which are not.
Read More
FIU-Jahresbericht 2025 – Wesentliche Entwicklungen im Überblick FIU Annual Report 2025 – Key Developments at a Glance
Read More

FIU Annual Report 2025 – Key Developments at a Glance

Germany's FIU recorded a historic number of suspicious activity reports in 2025, while the number of analytical reports declined significantly. Alongside new regulatory requirements and a stronger international focus, neobanks have emerged as a key pillar of reporting activity. This article analyses the most important developments and highlights the questions that remain unanswered in the annual report.
Read More
EuGH schafft Klarheit: Nicht jede Weiterleitung von Geldern Dritter ist ein Zahlungsdienst im Sinne der PSD2 ECJ Clarifies the Scope of PSD2: Not Every Transfer of Third-Party Funds Constitutes a Payment Service
Read More

ECJ Clarifies the Scope of PSD2: Not Every Transfer of Third-Party Funds Constitutes a Payment Service

The ECJ has further clarified the distinction between payment services and other business models. The judgment confirms that merely receiving and forwarding third-party funds does not automatically trigger licensing requirements under PSD2. The decision provides greater legal certainty for FinTechs, platform operators and other businesses handling payment flows, while emphasising that the specific business model remains decisive.
Read More